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Theodore J. Zeller III
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Theodore J. Zeller III
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The Aftermath of the Government Shutdown on TTB Processing Times for Breweries, Distilleries and Wineries

Brewer
Government Shutdown
Special Ruling
New Jersey
Breweries
Wineries
Distilleries

The United States federal government shutdown is nearly one month in our history, and we finally have some clarity regarding the shutdown’s effect on TTB permit application processing times. On February 21, 2019, the TTB updated its website listing the average number of days it takes to process TTB original permit applications.  Whether you are opening a brewery, distillery, winery, wholesaler, or any number of business regulated under the TTB’s permitting process, these average processing times are a great tool to determine how soon you must file your applications to open your new business or new location.

As of February 21, 2019, the following is the breakdown of processing times for brewery, winery, and distillery permit applications:

 

  • Brewery: 86 days (filed in November 2018), 83 days (filed in December 2018), 105 days (filed in January 2019 – during the shutdown);
  • Bonded Winery: 85 days (filed in November 2018), 92 days (filed in December 2018), 94 days (filed in January 2019 – during the shutdown);
  • Distillery (Distilled Spirits Plant): 71 days (filed in November 2018), 88 days (filed in December 2018), 142 days (filed in January 2019 – during the shutdown).

From this update, you can clearly see the effect the shutdown had on processing times.  At one point in 2018, brewery processing times were around 40 days and now it can take an average of 105 days if the permit application was filed in January 2019.  Distilleries took the biggest hit from the government shutdown, with the average processing time from November 2018 to January 2019 filings increasing from 71 to 142 days, doubling the average processing time over 3 months.  I am surprised the processing times for breweries and wineries did not increase more, but it is nice to have some information for clients that want to know when they can get approval.

Since the shutdown, the TTB has regularly updated its website for the average number of days to receive a Certificate of Label Approval (“COLA”), and the processing times have steadily been reduced in the last month.  For example, the average processing time for a malt beverage COLA was as high as 50 days post-shutdown, and has come down to 29 days as of February 21, 2019.

Ultimately, without the hard work of the employees at the TTB, who were all extremely busy prior to the shutdown, these average processing times could be much higher.  It cannot be easy to come back to work knowing how much of a backlog you will face and still get the job done without too much additional delay.  I would assume, due to the diligent work of the TTB employees, that the permit processing times will keep getting reduced as the COLA processing times have post-shutdown.  It just might take a little longer than originally anticipated.  This is why proper planning is key when starting an alcohol manufacturing business; you do not want to be ready to open and not have your permits approved for you to do so.

For information regarding national and state liquor law matters or general manufacturing and distribution advice, please contact our Liquor Law, Licensing, Manufacturing, and Distribution Practice Group: Liquor Law Department Chair Theodore J. Zeller III, Esquire (tzeller@norris-law.com); David C. Berger, Esquire (dberger@norris-law.com) for Pennsylvania and New Jersey retail and manufacturing licensing; or contact our offices at 610-391-1800.

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Theodore J. Zeller III
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Theodore J. Zeller III
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