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Three – Tier system, Controlled States and TTB in USA

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13/02/2019 Liquor control and government mechanisms explained for trading in the USA.

Three tier system involves alcohol distribution after the repeal of prohibition in the USA. It includes importers/producers, distributors and retailers. As per the three-tier system, producers can sell their alcohol only to wholesale distributors who then can sell further to retailers. A producer cannot sell alcohol directly to the retailer as per this law. Producers include brewers, winemakers, distillers, and importers.

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There are some states which have become ‘alcoholic beverage control jurisdictions’ after prohibition. In these states, distribution tier (part or all) is operated by the state government, sometimes retailing tier too is operated by state government.

The only state with privately operated retailing and distribution system that does not apply the three-tier system is the State of Washington.

Seventeen states and jurisdictions in Alaska, Maryland, Minnesota and South Dakota adopted forms of the "Control" model. Liquor control states include Alabama, Idaho, Iowa, Maine, Michigan, Mississippi, Montana, Montgomery County-MD, New Hampshire, North Carolina, Pennsylvania, Ohio, Oregon, Utah, Virginia, Vermont, West Virginia and Wyoming.

Another important element is, The Alcohol and Tobacco Tax and Trade Bureau, statutorily named the Tax and Trade Bureau (TTB). It is a bureau of the United States Department of the Treasury, which regulates and collects taxes on trade and imports of alcohol, tobacco, and firearms within the United States.

TTB COLA is the Certificate of Label Approval/Exemption (COLA) for your product. It makes sure that alcohol products are created, labeled, and marketed in accordance with Federal laws and regulations. COLAs Online is an internet-based system wherein registered industry members can apply online for the certificate of label approval, exemption from label approval or distinctive liquor bottle approval. The Public Cola Registry is the public module of the COLAs online system and it requires no username or password. Copies of approved electronic and paper application is available in the module. One can take prints, if available. 

In short, any supplier who wants to ship a bottle or even a sample, can’t ship it unless they have an importer. Hence, for this, TTB issues the license for the supplier to ship it. Food and Drug Administration (FDA) number is required to get TTB COLA which will further help them to enter the USA.

Sources: National Alcohol Beverage Control Association (USA)

                   Alcohol & Tobacco Tax & Trade Bureau (TTB - USA)