BA: “Special Attention” Needed for Small Brewers Under New TTB Rulemaking Proposals

Dear Client:  Just before the weekend, the Brewers Association submitted formal comments to the TTB on two major rulemaking proposals that could reshape alcohol labeling nationwide. Recall, through a beer lens, the first proposal, TTB Notice 237, would require most beer that crosses state lines to carry mandatory “Alcohol Facts” panels similar to food nutrition labels. And the second, Notice 238, would require mandatory disclosures of any of the “big nine” food allergens on beer in interstate commerce as well.