On January 10, 2025, the Alcohol and Tobacco Tax and Trade Bureau (TTB) introduced two new rules in the Federal Register, bringing significant changes to the packaging standards for distilled spirits. This new regulation authorizes additional standards of fill for containers, granting producers and importers greater flexibility in selecting container sizes. By expanding these options, the rule is expected to streamline the movement of goods in both domestic and international markets while also providing consumers with more diverse choices. Additionally, it removes the distinction between cans and other containers, simplifying the regulatory landscape for distilled spirits packaging. This shift aims to enhance efficiency and offer both producers and consumers a broader range of possibilities. The USA Spirits Ratings delves deeper into the key aspects of this new rule and its implications for the industry.

Key Changes in the Final Rule

The TTB’s latest update allows for the approval of 15 additional standards of fill, expanding the available container sizes for distilled spirits. These additions include new volumes, such as 187, 250, 331, 350, 355, 475, 500, 570, 700, 710, and 945 milliliters, as well as larger sizes like 1.5, 2, 3, and 3.75 liters. By implementing these changes, TTB is responding to requests from industry members for more flexibility and variety in container sizes.

The rule also resolves the longstanding distinction between standards for cans and other types of containers. Previously, different standards applied to canned and non-canned distilled spirits. However, under the new rule, the same standards of fill apply across all container types, creating a more streamlined and consistent regulatory framework.

Image: Canned Beverages

Why TTB Made These Changes

The TTB's decision to introduce additional container sizes comes after significant input from industry professionals. In May 2022, TTB issued a proposal (Notice No. 210) to eliminate size restrictions for distilled spirits. This proposal received mixed feedback. Supporters argued that removing the regulations would lower costs for producers, facilitate international trade, and provide consumers with more packaging options. On the other hand, some opponents voiced concerns about the potential for consumer confusion and the difficulties in forecasting demand for a broader range of bottle sizes.

After careful analysis of these comments, TTB opted not to eliminate all standards of fill. Instead, they decided to authorize a range of new sizes that offer flexibility without disrupting the market. The final rule incorporates many of the sizes suggested by industry stakeholders, addressing their need for greater packaging options while avoiding the confusion that could arise from completely removing the standards.

Also read: The Power of Packaging—How it Can Impact Your Brand's Success

Industry Response and Concerns

While many producers welcomed the move to allow for more container sizes, others expressed concerns. For instance, the Mexican Chamber of the Tequila Industry highlighted the challenges of managing inventory and forecasting demand for a wider range of sizes, particularly for smaller producers. They also noted that standardized container sizes have been beneficial for promoting production efficiency and environmental sustainability.

On the other hand, some industry professionals pointed out that introducing larger container sizes could reduce waste, increase profitability, and provide consumers with better value. These comments reflect the industry’s desire for packaging flexibility that meets consumer demand while being economically and environmentally sustainable.

Image: Different types of spirits on display

The Importance of Maintaining Consumer Confidence

A significant portion of the feedback from both supporters and opponents of the proposed changes centered on consumer confusion. Opponents argued that eliminating size standards entirely could lead to a confusing array of container sizes, making it difficult for consumers to compare prices effectively and increasing the risk of “shrinkflation” (where the product amount decreases but the price remains the same).

In response to these concerns, TTB decided to maintain the standards of fill for distilled spirits, ensuring that recognizable and familiar sizes remain available in the market. This decision aims to balance the need for greater flexibility with the need to protect consumers from confusion and pricing discrepancies.

Addressing State-Level Concerns

Another consideration that influenced the TTB’s decision was the potential for conflicting state regulations. Some states currently defer to federal standards for container sizes, and removing the standards could lead to a patchwork of state rules. This could cause further confusion for producers, distributors, and consumers. By approving a range of new sizes while maintaining core size standards, TTB aims to avoid such disruption.

More Choices for Consumers

Despite the concerns voiced by some industry members, TTB believes that the new rule will ultimately provide more options for consumers without compromising the overall structure of the market. The added flexibility will allow distillers to offer a wider array of packaging options, catering to different consumer preferences and needs.

Also read: A Taste of Time—Award-Winning BHAKTA Spirits' Vintage Blends of Armagnac and Global Recognition

The New Standards of Fill

The new TTB rule allows for the following standards of fill for distilled spirits containers: 3.75 liters, 3 liters, 2 liters, 1.8 liters, 1.75 liters, 1.5 liters, 1 liter, 945 ml, 900 ml, 750 ml, 720 ml, 710 ml, 700 ml, 570 ml, 500 ml, 475 ml, 375 ml, 355 ml, 350 ml, 331 ml, 250 ml, 200 ml, 187 ml. 100 ml and 50 ml. 

The TTB’s final rule represents a compromise between flexibility for producers and the need for consumer protection. By expanding container size options while maintaining core standards of fill, the new rule strikes a balance that promotes industry growth and innovation without sacrificing consumer confidence. For beverage producers and importers, these changes represent an exciting opportunity to diversify their product offerings and explore new markets, both domestically and internationally. At the same time, consumers can look forward to more choices and greater transparency when it comes to purchasing distilled spirits.

This final rule is a significant step toward modernizing the distilled spirits industry, paving the way for a more adaptable and competitive market. The industry now has greater freedom to innovate with packaging while ensuring that consumers remain informed and protected.

Header image sourced from Unsplash

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