TTB Announces Extension of Hand Sanitizer Guidance

In a special edition of its newsletter, the Alcohol and Tobacco Tax and Trade Bureau (TTB) announced it would extend exemptions, waivers, and other authorizations from its March 26 guidance on hand sanitizer, to align with the CARES Act.

Here is the complete announcement:


On March 26, 2020, TTB issued guidance providing certain exemptions and waivers to distilled spirits permittees to facilitate the production of alcohol-based hand sanitizers, see TTB G 2020-1A, Production of Hand Sanitizer to Address the COVID 19 Pandemic.

On March 27, 2020, the CARES Act was signed into law, providing for additional flexibility with regard to removals of distilled spirits free of tax for use in or contained in hand sanitizer that is produced and distributed in a manner consistent with Food and Drug Administration guidance related to COVID-19.

We are therefore working to update our original guidance and also provide guidance on the additional flexibilities of the CARES Act. In the interim, we are extending any exemptions, waivers, or other authorizations currently provided in TTB G 2020-1A, through December 31, 2020.


In response to state and local stay-at-home orders, and for the safety and protection of our employees in the context of the COVID-19 pandemic, all TTB laboratories are temporarily closed, pending further notice.

Due to these closures, we will not be able to process product samples or paper submissions sent to the laboratories via mail until they reopen. Therefore, we are providing the following options to facilitate industry members’ ability to get their products to the marketplace, including through the electronic submission of information wherever possible, until the TTB laboratories reopen.

We are currently evaluating additional options to minimize delays for affected industry members as a result of the temporary closure of the laboratories during the pandemic, and we will update this information as appropriate.

Laboratory Sample Analysis. During the laboratory closures, We are temporarily unable to process formula applications for alcohol beverage products, nonbeverage products, or denatured alcohol that require product samples. We will continue to process formulas that do not require laboratory sample analysis and encourage industry members to submit those formulas electronically in Formulas Online. For additional information, please review our online resources on formula requirements, including a List of Alcohol Beverages that Require Formula Approval with Lab Analysis, as well as information about nonbeverage drawback formulas and SDA formulas.

Sulfite Waiver Analysis for Domestic and Imported Wines. Until the laboratories reopen, we will not be able to analyze samples of domestic and imported wine products that bottlers or importers assert contain less than 10 parts per million total sulfur dioxide and, therefore, are not subject to mandatory sulfite labeling declarations. The review of requests for sulfite waiver testing and label approval for such claims for certain wines will accordingly be delayed.

Gluten Analysis. To avoid delays in determinations regarding gluten analyses during the laboratory closures, industry members are encouraged to submit supporting documentation for certain gluten content claims electronically to for review. See TTB Ruling 2014-2 for more information about gluten content claims. Determinations on paper submissions sent by mail to the laboratories will be delayed until they reopen.

Proofing Device Requests. Distilled spirits proprietors who wish to use a proofing device other than the devices already recognized in our regulations and in TTB guidance should submit their information electronically to for review and processing.

Chemist Certification Program. The TTB Chemist Certification Program is a voluntary program that certifies private industry chemists to analyze wine, distilled spirits, and beer for export. We issue a call for applications twice a year, in the spring and fall. The 2020 spring cycle is cancelled due to the TTB laboratory closures. Applications that have already been sent for the spring cycle will automatically be considered for the fall cycle. Potential applicants who have not yet applied should apply for consideration in the fall. Updates will be provided if there are any changes to the fall schedule.

Chemist certifications are valid for two years. Any certifications that are due to expire by June 30, 2020, are extended until December 31, 2020.

If a delay in obtaining or renewing this certification presents challenges to any industry member’s operations, please note that export analyses can still be performed by other currently certified chemists listed on, or you may contact us with questions through

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