Treasury Eyes Booze Chemists' Export Testing Paperwork
Published Date: 3/28/2025
Notice
Summary
The Treasury Department is asking for public feedback on forms and records used by alcohol and tobacco businesses, especially for chemists who test beverages for export. These updates help keep testing reliable and meet international rules, with comments due by April 28, 2025. This affects labs, brewers, and others who want to export alcohol, ensuring smooth trade without extra costs or delays.
Analyzed Economic Effects
10 provisions identified: 5 benefits, 5 costs, 0 mixed.
Voluntary chemist certification helps exports
TTB runs a voluntary Chemist Certification Program that labs, chemists, enologists, brewers, and technicians can use so many foreign countries will accept their reports of analysis. The collection covers applications, test results, requests for TTB-affirmed reports, notices of employment changes, and recordkeeping; TTB estimates 275 respondents, 275 total responses, and 275 total burden hours.
Ongoing special occupational tax registration rules
Wholesale and retail alcohol dealers must register (and update registrations when starting, ending, or changing business) and certain tobacco manufacturers and cigarette paper/tube makers must register and pay an annual special occupational tax (SOT); registrations and SOT payments are due on or before the date of commencing business and on or before July 1 each year. TTB estimates 6,545 respondents and 6,545 annual responses for this collection.
Claims process to refund or adjust excise taxes
Taxpayers may file TTB Form 5620.8 to claim refunds or relief from excise taxes on distilled spirits, wine, beer, and tobacco products that were lost, destroyed, returned, or used in nonbeverage products; TTB estimates 5,000 respondents and 5,000 total responses with 5,000 total burden hours.
Reporting removals of tobacco products for export without tax
Tobacco product and cigarette paper/tube manufacturers and export warehouse proprietors must report removals without payment of tax on TTB Form 5200.14 or use an approved Monthly Summary Report procedure; TTB estimates 300 respondents, 21,970 responses, and 27,730 total burden hours.
Label and bottle approvals required before sale
Before introducing an alcohol beverage into interstate or foreign commerce, producers, bottlers, or importers must apply for and receive label approval (a Certificate of Label Approval or COLA) or apply for an exemption using TTB Form 5100.31 or the electronic COLAs Online system; TTB estimates 12,750 respondents, 209,100 total responses, and 108,035 total burden hours for this collection.
Excise tax returns for Puerto Rico shipments
Products manufactured in Puerto Rico and brought into the United States must use TTB Form 5000.25 to report and pay excise taxes under 26 U.S.C. 7652(a); TTB estimates 24 respondents averaging 19.75 responses each for a total of 474 responses and 356 burden hours.
Form to offer compromises for FAA Act violations
Persons alleged to have violated the Federal Alcohol Administration (FAA) Act can submit an Offer in Compromise using TTB Form 5640.2 to propose a monetary settlement and the reasons for the offer; TTB estimates 10 respondents and 10 total responses with a total burden of 20 hours.
Offers in compromise and financial statements for tax liabilities
Under 26 U.S.C. 7122, persons may submit offers in compromise for tax liabilities to TTB on TTB Form 5640.1, and to request installment payment plans they may submit financial information on TTB Forms 5600.17 (individuals) or 5600.18 (businesses); TTB estimates 80 respondents, 80 responses, and 190 total burden hours for these collections.
Drawback claims for exported tobacco products
Persons who paid Federal excise tax on tobacco products, cigarette papers, and tubes and later export those products may file drawback claims using TTB Form 5620.7 and file the required bond on TTB Form 5200.17; TTB estimates 13 respondents, 13 responses, and 18 total burden hours for this collection.
Changing bonds (change of surety) requirement
Proprietors required to post bonds under various Internal Revenue Code sections must file TTB Form 5000.18 when changing the terms of a bond or changing surety; TTB estimates 120 respondents and 120 total responses with a total burden of 120 hours.
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