Nonbeverage Products Laboratory Overview Rachel K. Sanderoff, Chemist

NPL Mission To provide the quality data and technical support required by TTB and industry members Protect the public Collect the revenue through processing formulas and analyzing samples for nonbeverage and tobacco products

Organization John Manfreda Administrator Vicky McDowell Asst. Administrator Bill Foster Asst. Administrator Headquarters Operations Abdul Mabud Director Scientific Services Division Janet Scalese Chief Nonbeverage Products Lab Management/Chief Financial Officer Chief of Staff Industry Liaison Field Operations Knowledgement Management Staff Regulations and Rulings Division Advertising, Labeling, and Formulation DivisionInternational Trade Division Jeffrey Ammann Chief Beverage Alcohol Lab Norma Hill Chief Compliance Monitoring Lab

NPL Organization Michelle Williams-Ellerbe Legal Instruments Examiner Janet Scalese Chief Edward Limowski Chemist Julie Arthur Chemist John Shifflett Chemist Tomika Moore Senior Chemist Dawit Bezabeh Senior Chemist Rachel Sanderoff Chemist

Products Nonbeverage (Drawback) Alcohol Food, flavor, medicine, medicinal preparations, perfumes Food, flavor, medicine, medicinal preparations, perfumes Manufacturer pays excise tax on purchase of ethanol Manufacturer pays excise tax on purchase of ethanol File formula and claims for return on some of the tax File formula and claims for return on some of the tax

Products Specially Denatured Alcohol (SDA) Alcohol containing other chemicals which denature it to make it unfit Alcohol containing other chemicals which denature it to make it unfit (27 CFR Part 20 and 21) Companies must have permit and approved formula Companies must have permit and approved formula Tobacco Laboratory analysis to determine tax classification

Actions on Drawback Formulas APPROVED (Domestic) – alcohol eligible for drawback, unfit for beverage purposes APPROVED (Domestic) – alcohol eligible for drawback, unfit for beverage purposes NO ACTION (Domestic) – no alcohol eligible for drawback, unfit for beverage purposes NO ACTION (Domestic) – no alcohol eligible for drawback, unfit for beverage purposes APPROVED/NO ACTION (Foreign) – alcohol eligible for 5010 tax credit, unfit for beverage purposes. APPROVED/NO ACTION (Foreign) – alcohol eligible for 5010 tax credit, unfit for beverage purposes.

DISAPPROVED (Domestic) – alcohol is NOT ELIGIBLE for drawback, fit for beverage purposes, cannot be sold to another company DISAPPROVED (Domestic) – alcohol is NOT ELIGIBLE for drawback, fit for beverage purposes, cannot be sold to another company DISAPPROVED (Foreign) – alcohol NOT ELIGIBLE for 5010 tax credit, fit for beverage purposes DISAPPROVED (Foreign) – alcohol NOT ELIGIBLE for 5010 tax credit, fit for beverage purposes RETURNED – sample needed, information not complete, etc. RETURNED – sample needed, information not complete, etc. Actions on Drawback Formulas

“Fitness” Fit for beverage purposes = the average person might mistake the product for an alcoholic beverage Fit for beverage purposes = the average person might mistake the product for an alcoholic beverage Evaluation of fitness Evaluation of fitness Evaluate formula on paper using guidelines Evaluate formula on paper using guidelines Analyze ingredients Analyze ingredients As a last resort, dilute to 15% EtOH and taste As a last resort, dilute to 15% EtOH and taste

More Information More specific information and guidelines for “unfitness” will be discussed later in Ed’s and John’s presentations. More specific information and guidelines for “unfitness” will be discussed later in Ed’s and John’s presentations.