During a shutdown, TTB would not process or work on any Certificate of Label Approval (COLA) applications, formula approvals, permit applications, or laboratory service requests. The previous government shutdown created significant backlog and delays in processing the above applications/approvals. The TTB specialists did their best to get back to normal (kudos to them), but there were still numerous negative impacts from the shutdown.
For example, consider a start-up brewery that may have negotiated free rent for a certain period, with the expectation that it would obtain full licensure and be able to operate during those months. A government shutdown would delay the permitting process and, in a sense, negate the benefit of the free rent period.
Or consider if an established brewery or distillery has plans for new seasonal products but has yet to secure COLAs. A government shutdown could prevent these seasonal products from going to market in a timely manner because of the inability to get COLAs.
There are numerous potential negative impacts from a shutdown. Industry members should start planning now for how to deal with the potential consequences of a shutdown.
Congress has until Nov. 17 to reach a deal.