Greenspoon Marder Hospitality, Alcohol & Leisure Blog: TTB and Hand Sanitizer Guidance for Holders of Distilled Spirits Permits (DSP’s)

Mar 19, 2020

As a result of the shortage of hand sanitizer due to Covid-19 the Acting Administrator of TTB issued a communication yesterday evening allowing holders of Distilled Spirits Permits (DSP’s) to immediately commence production of hand sanitizer or distilled spirits for use in hand sanitizer without having to obtain any prior authorization. The waiver does away with the holder of the DSP from having to obtain additional permits or bonds. DSP holders can either manufacture the hand sanitizer or sell the necessary distilled spirits to permitees for the production of sanitizer.

As part of the waiver, hand sanitizer products are not subject to federal excise tax if made with denatured ethanol. If made with undenatured ethanol, federal excise tax must be paid. TTB went further and listed the ingredients permitted in hand sanitizer for production by holders of DSP’s. The permitted hand sanitizer (without obtaining approval) may be comprised of:

denatured or undenatured ethanol,
glycerol (not less than 1.45% of the finished hand sanitizer product on a volume basis), and
hydrogen peroxide (not less than 0.125% of the finished hand sanitizer product on a volume basis).

The initial waiver will remain in effect until June 2020 and may be extended as necessary.

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Greenspoon Marder Hospitality, Alcohol & Leisure Blog: TTB and Hand Sanitizer Guidance for Holders of Distilled Spirits Permits (DSP’s)

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