TTB Compliance refers to the regulatory and tax requirements administered by the Alcohol and Tobacco Tax and Trade Bureau (TTB), a bureau of the U.S. Department of the Treasury. TTB authority derives from the Internal Revenue Code (26 U.S.C. Chapters 51 and 52) and the Federal Alcohol Administration Act (27 U.S.C. § 201 et seq.).
Permits required to import:
- Importer's Basic Permit under the FAA Act — required for distilled spirits, wine, and malt beverages for non-industrial use
- Tobacco Importer Permit under 26 U.S.C. § 5712 — required for tobacco products and cigarette papers/tubes
Federal excise tax (FET): Imported alcohol and tobacco are subject to federal excise tax in addition to customs duty, payable at the time of importation:
- Distilled spirits: $13.50/proof gallon (with reduced rates for first 100,000 proof gallons under CBMA)
- Wine: $1.07–$3.40/gallon depending on alcohol content
- Beer: $18.00/barrel (with reduced rates for first 6 million barrels)
- Cigarettes: $50.33/thousand
- Cigars: variable by weight and price
Label approval — Certificate of Label Approval (COLA): Most alcohol beverage labels must receive TTB COLA approval before importation under 27 CFR Parts 4, 5, and 7. The label must include mandatory information: brand name, class/type, alcohol content, net contents, name and address of importer, country of origin, and Government Health Warning Statement.
Formula approval: Certain products (flavored spirits, agave-based spirits, beer with non-traditional ingredients) require pre-import formula approval from TTB.
Interaction with CBP: Imported alcohol and tobacco require entry summary filing through ACE with TTB-specific data elements. Goods without proper TTB permits, COLA, or paid FET are detained at the port and may be seized under 19 U.S.C. § 1595a.
Importers face dual exposure — TTB civil penalties under 26 U.S.C. § 5761 and CBP penalties under Section 1592 — for non-compliance. Effective reasonable care over TTB requirements is non-negotiable for any alcohol or tobacco import program.