On January 17, 2025, TTB published two proposed rules that will eventually put per-serving alcohol, calorie, and nutrient counts, plus a nine-allergen disclosure, on every spirits label in the country. The comment period, extended once after trade groups asked for more time, closed August 15, 2025. TTB's own regulatory agenda then set a target of finalizing both rules by May 2026. May 2026 came and went. The most recent tracking now points to March 2027. Neither rule has published.
Most brand operators read that timeline and conclude the opposite of what it actually means: not final, not urgent, nothing to do yet. Wait for the headline, then react.
Here's the problem with that read. This rulemaking has already blown through one federal deadline TTB set for itself, and it's now tracking toward a second target a little over two years after the proposed rules first published. That's not a stalled process. That's a rule that keeps missing its own finish line while still moving toward it. Spirits label approvals (COLAs) are currently running around a seven day median turnaround, but that's under normal filing volume. It tells you how TTB operates day to day. It tells you nothing about what happens the day every spirits brand in the country needs its SKUs relabeled at once.
The mechanics, once it lands: an Alcohol Facts panel on every SKU, per-serving alcohol, calorie, and nutrient content, plus mandatory disclosure of nine major allergens, milk, eggs, fish, crustacean shellfish, tree nuts, wheat, peanuts, soybeans, and sesame, and any protein derived from them used in production. That's not a pricing adjustment you absorb next quarter. That's every label on every SKU redesigned, on a federal clock you don't control.
Even the people arguing about this rule aren't arguing your side of it by default. ACSA, representing craft producers, backs the allergen disclosure piece but has formally asked TTB to exempt small distilleries from the nutrient panel, arguing the compliance cost lands hardest on producers least able to absorb it. Whether that exemption survives into the final rule is still open. If you're a small or mid-size operator, that fight is happening right now, with or without your input.
The uncomfortable question: if the one number you're relying on to justify inaction, when this becomes final, is a number TTB has already missed once, how much runway do you actually think you have?
What to do about it:
Track this yourself. Check federalregister.gov or ttb.gov for rulemaking status every quarter rather than waiting for a trade headline to tell you it finalized.
Ask your ingredient suppliers now whether any major allergen protein survives your production process. That answer determines whether you're filing for an exemption or redesigning around a disclosure.
Read ACSA's actual comment letter to TTB. Know what's already being argued on your behalf, and where it falls short of what you'd argue yourself.
Off-Invoice is a free newsletter from Barrel & Beacon, built for spirits brand operators navigating distribution, sales, and the real economics of the three-tier system. If someone forwarded this to you, subscribe here.Off-Invoice is a free newsletter from Barrel & Beacon, AI operations for beverage brands.