As of this writing there is still the possibility of a government shutdown going into effect on October 1st. If that does happen it would mean that TTB staff won’t be working reviewing permit applications, label approval applications or available to respond to contacts from industry members.
But for wineries it would still continue to be business as usual for any and all of their TTB application or report filings. Across the board it would be in the best interest of all wineries to continue to file any necessary applications via Permits Online specific to their basic permit, and any label approval applications (COLAs). While both of these types of applications won’t be looked at by TTB staff if the shutdown is in effect, they will at least be in their queue and it is generally always better to be earlier than later in the TTB’s queue! All applications would be reviewed in “the order they were received” once TTB staff were back at work.
The two other reports
that US wineries are required to file, the Report of Wine Premise operations (5120.17) and Excise tax wineries will need to continue to file on the filing frequency that fits their activity level. Simply because the TTB is away doesn’t mean that wineries can play. A government shutdown does not affect the requirement to file these reports. Both of these reports wineries can file electronically via Pay.Gov
. (unless they are still stuck in the old school paper world, which the TTB does still accept)
Let’s hope for everyone concerned that this event does not happen. But if it does, wineries just need to be aware of what they need or want to keep filing. Our course The TTB Reports all US Wineries are Required to File is a broad and practical overview of the 3 reports that all US wineries need to understand.