Proposed Rule Comments: Alcohol and Tobacco Tax and Trade Bureau; Consideration of Updates to Trade Practice Regulations (88 Fed. Reg. 1,171, January 9, 2023)

The U.S. Chamber of Commerce submits these comments in response to TTB’s Advance Notice of Proposed Rulemaking (ANPRM) regarding competition in the beer, wine, and spirits industry. Although we always appreciate the opportunity to share our views, and though we agree with portions of the ANPRM, we encourage TTB largely to abandon this effort.

First, and most importantly, TTB lacks legal authority to proceed on most of the topics set forth in the ANPRM.

Second, there is no need for new regulations because competition is already thriving in these markets. Third, as the ANPRM recognizes has happened in the past, new regulations carry a significant risk of discouraging competition. Instead of promulgating new regulations, therefore, TTB should focus its resources on reducing existing regulatory barriers to promote competition. 

Download and read the full comments.