As any US-based distilled spirit enthusiast knows too well, many great bottles don’t make it to our shores for several reasons. One particularly frustrating reason is bottle sizes. Here in the U.S., the government, in the form of the Tax and Trade Bureau (TTB) only allow certain bottles sizes for distilled spirits. The allowed sizes50ml, 100ml, 200ml, 375ml, 750ml, 1 liter, and 1.75 liters
Meanwhile, in most of the rest of the world, a 700ml bottle is the “standard” size, meaning such bottles can’t legally be imported into the U.S. Many spirit brands can’t afford or don’t want to bottle multiple bottle sizes, so U.S. based consumers are out of luck.
Recently, the TTB put forth a proposal to eliminate the various “standards of fill” i.e. allowed bottle sizes, thus opening the U.S. market to more products. My previous story elaborated on the proposal and its potential impact. As with all such proposals, public commentary was sought, and a deadline for comment set.
The comment deadline has now passed, and because all submitted comments can be publicly viewed, it’s worth looking at who advocated for what. What follows is an annotated version of a summary sent to WIRSPA member distilleries:
Note: Each link directly opens the PDF that was submitted to the TTB.
- US based craft distilling groups (ACSA, American Coalition of Craft Beverage Importers) were broadly in support of the complete elimination of standards of fill (SOF).
- US distributors, wholesalers, retailers, licensees, and US brands (Sazerac, Heaven Hill, WSWA, Southern Glazer’s) as well as the association of control states were fully opposed to any change, specifically citing consumer confusion and citing the 700ml size as a way for non-US producers to get an advantage over local brands. Also, the cost of maintaining additional SKUs.
- International drinks bodies (Scotch Whisky Association, Tequila, BNIC (Cognac), Spirits Canada) and DISCUS supported the maintenance of SOF but wished to continue to consult on how a system to consider new sizes could work. SWA was the only one who suggested another look at 700ml. The European Union also agrees with this approach.
- Diageo, Bacardi and Remy Cointreau all made submissions supporting the existing SOF but asking for some limited additions, similar in intent to WIRSPA’s submission, which suggested additional sizes: 350ml, 500ml; 700ml; 1.5 liter.
- Two EU based brands – Campari and Moet Hennessey – made individual submissions. Both were strongly opposed to any change, and specifically to adding the 700ml size, which they saw as a route to unauthorized grey market imports, counterfeit product, and potential for US tax losses.
In short, large, well-established entities were opposed to eliminating the standards of fill, or just for allowing a few more standards of fill to be included. Disrupting the current system was often cited,which includes the trouble of keeping track of more SKUs.
Smaller entities and enthusiasts were much more likely to be in favor of eliminating the SOF.
As I write this, the TTB has not announced any formal decision on the proposal. I’ll update here when they do.
Regardless of your position on the issue, reading public comments on various TTB proposals can be fascinating reading. It’s a rare glimpse into companies and organizations starting unvarnished opinions, and mostly devoid of marketing spin.