Important Update for New Jersey Alcohol Manufacturers: Changes to Brand Registration and Renewal Process
On June 26, 2024, the New Jersey Division of Alcoholic Beverage Control issued an amended advisory notice (AN 2024-04) regarding the product/brand registration and renewal process. This notice amends the previous advisory (AN 2022-03) issued on Dec. 19, 2022, addressing industry concerns and technical matters related to the new brand registration renewal process.
Key Changes Effective Immediately
The elimination of alternative "product ID" numbers is a major change. Previously, brand registrants could use alternative "product ID" numbers for internal inventory control if a Universal Product Code (UPC) was unavailable. This practice is no longer permitted. Registrants must now amend their brand registrations if they previously used alternative "product ID" numbers. The Division’s POSSE system will generate a unique identifying number for products without a UPC. Amendments to correct these alternative IDs are free until July 31, 2024, after which a $10 statutory fee per amendment will apply.
Another critical change is the unique UPC requirement. A UPC number, which must contain 12 or more digits, can be associated with only one product. Using the same UPC for multiple products is not allowed. Registrants who have registered multiple products under a single UPC must amend their registrations by July 31, 2024, to avoid the $10 amendment fee. The POSSE system will prevent the completion of brand registrations if a unique UPC is assigned to more than one product.
Procedures for Amendments
To amend alternative "product ID" numbers, registrants will log into the POSSE system, navigate to the Product/Brand Registration page, and use the UPC Update Amendment icon. For UPC amendments, if the same unique UPC number is attempted for multiple products, the registrant will receive an error message. They may then use the system-generated number or terminate the existing brand registration to reuse the UPC for a different product not being sold in New Jersey.
Impact on Compliance
Every licensee selling or offering alcoholic beverages to retailers must ensure their products have a valid brand registration number listed on the Current Price List (CPL). Failure to comply can result in the product being disallowed for sale in New Jersey.
Conclusion
These changes emphasize the importance of accurate and unique product identification for regulatory compliance and data integrity. Manufacturers must promptly update their brand registrations to align with the new requirements, ensuring a seamless transition and avoiding potential fees.
By staying informed and proactive, New Jersey alcohol manufacturers can ensure compliance and avoid disruptions in their business operations.