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The National Association of Beverage Importers, Inc. (NABI) is a national trade association representing the interests of beer, wine and spirit importers at state and federal levels. Our mission is to help the importer members operate their businesses more efficiently and profitably by providing timely information, aggressive representation, and thoughtful advice on technical and political matters.

Learn more about NABI membership or if you have a question about importing an alcohol beverage into the United States, please do not hesitate to call us at (202) 393-6224 or email nabipresident@bevimporters.org

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World Trade Organization  - Airbus and Boeing Trade Disputes - Retaliatory Tariffs

On May 7, 2020, USTR announced it notified the World Trade Organization (WTO) that the United States has fully complied in the proceeding brought by the EU on improper subsidiaries to Boeing as the result of the recent repeal of the disputed tax law by the State of Washington. If the WTO agrees, then the United States asserts the EU would have no right to impose retaliatory tariffs. The Boeing action is significant because one reason delaying negotiations in the Airbus trade dispute is the leverage in negotiations the EU would receive from Boeing retaliatory tariffs. U. S. Trade Representative Ambassador Lighthizer stated “We will continue to press the EU to negotiate a resolution that respects the WTO’s findings” in the Airbus dispute.

NABI Letter to USTR on U.S./United Kingdom Trade Agreement Negotiating Objectives

NABI submitted a letter, dated January 15, 2019, to the Office of the United States Trade Representative (USTR) pointing out the areas where current trade agreements relating to wines and distilled spirits with the European Union need to be made applicable to the United Kingdom once the latter leaves the European Union.  Thanks to the NABI Members who commented on the draft comment letter that was circulated last week.  The comment letter is on the public record file at:  https://www.regulations.gov/document?D=USTR-2018-0036-0131   



News Release         (May 20, 2020)

NABI Seeks Regulatory Policy on Parity in Comment Letter to Customs and Border Protection in Response to Temporary Final Rule on Deferrals of Duties, Taxes, and Fees (USCBP 2020-0017)  

Today, the National Association of Beverage Importers (NABI) asked Customs and Border Protection (CBP) to use this rulemaking as the opportunity to establish a regulatory policy for parity of treatment between domestic producers and importers of distilled spirits, wine, and beer. NABI fully understands that the scope of the deferral in the Temporary final rule was limited by the parameters set forth in the Executive Order signed by the President on April 18, 2020. Nevertheless, “as CBP confronts similar situations in the future, the established regulatory policy on parity of treatment would be factored into decisions made by CBP and the Administration where there is no rationale for treating importers and domestic producers differently” said NABI President Robert Tobiassen.

In the Temporary final rule, CBP gave importers a 90-day deferral on the deposits of estimated duties, taxes, and fees on withdrawals for consumption made in March or April 2020, where the importer suffered significant financial hardship as a result of a full or partial shutdown order due to COVID-19. For the same excise taxes on distilled spirits, wine, and beer paid by domestic producers, the Alcohol and Tobacco Tax and Trade Bureau (TTB) gave a 90-day postponement of tax payments where the original due dates were on and after March 1 through July 1, 2020, with no other conditions.

“Importers without a doubt are core American businesses” said Tobiassen, “who are strong supporters of their local communities, especially in these difficult times, and strong employers in those communities. This action does not provide parity for those beverage alcohol importers whose domestic counterparts have already received a 90-day deferral of their excise tax payments from TTB and without establishing a significant financial hardship.” NABI noted that imported beverage alcohol that is transferred in bond to a TTB regulated premise is receiving the 90-day benefit from TTB. Excise taxes on these same imported products paid to CBP should have parity of treatment. NABI greatly appreciates the many efforts by CBP to minimize trade impairment during the COVID-19 crisis and looks forward to working with CBP on the parity policy matter. 

The comment letter is on public file at:  https://www.regulations.gov/document?D=USCBP-2020-0017-0007

For more information, contact NABI at (202) 393-6224 or nabipresident@bevimporters.org

NEWS RELEASE (May 6, 2020)

NABI and Beer Institute Seek Parity for Imported Beer on Waiver of Notice of Destruction in COVID-19 Crisis

In a letter, dated May 6, 2020, to Acting Commissioner Mark A. Morgan, NABI and the Beer Institute requesting administrative flexibility from Customs and Border Protection (CBP) on requirements for destruction of imported taxpaid beer under 19 CFR sections 190.35 and 190.71 and expedited handling of drawback request for that beer. More specifically, we request that CBP, like the Alcohol and Tobacco Tax and Trade Bureau (TTB), waive the notice requirement before an importer or importer’s agent may destroy imported taxpaid beer in the marketplace made unmerchantable by reason of the COVID-19 pandemic through July 1, 2020, and expedite drawback claims for destroyed beer.

In the interest of public safety due to the COVID-19, states and cities across the nation closed thousands of bars and restaurants as well as canceled sporting events, brew festivals, and more. There are many hundreds of millions of dollars of draught and other beer sitting at these venues that cannot be sold, will go stale, and must be retrieved and destroyed. All across the United States, domestic brewers and importers are working with their wholesale partners to relieve these on-premises accounts of the burden of these inventories of unmerchantable beer. Of course, brewers and beer importers must destroy this large quantity of beer. 

We also asked for expedited review and approval of drawback claims for this beer. Brewers and beer importers, who often operate on slim margins, continue to employ many talented people with jobs focused on on-premises accounts. Expediting drawback claims will help cash flow for brewers and beer importers of all sizes, operating in every corner of our nation, to continue to employ our neighbors, friends, and family.

Importers, either alone or through their agents, will maintain records to substantiate the destruction, including a serial number for each destruction that is then identified by reference on any drawback claims or adjustments when submitting a claim to CBP for drawback of federal excise tax or duty. The records will include a description of how the beer was destroyed as required under 19 CFR section 190.71(b) for non-supervised destructions.



News Release: NABI and Other Trade Associations Call for Equal Tax Treatment for Imports

For Immediate Release: 

April 27, 2020 

 

Beverage Alcohol Industry Calls for Equal Tax Treatment for Imports Amid COVID-19 Crisis to Protect Jobs

WASHINGTON — In a letter sent April 23 to Secretary of Treasury Steven Mnuchin, U.S. beverage alcohol associations urged the Administration to provide parity in the deferral of federal excise taxes payment for domestic and imported wine, beer and distilled spirits in response to the outbreak of COVID-19. 

Earlier this month, the U.S. Alcohol and Tobacco Tax and Trade Bureau allowed all U.S. distillers, brewers and vintners to delay their federal excise tax payments for 90 days, providing domestic producers with some liquidity in order to maintain workers and continue to contribute to the economy.

On Monday, Customs and Border Protection issued guidance for beverage alcohol importers allowing them to delay their federal excise tax payments only if they prove they have faced a more than 40 percent loss of revenue.

This onerous requirement and disparate guidance will mean importers—which support thousands of jobs in the United States—will not have the capital that is critical for all businesses to protect jobs.

The letter requests Customs of Border Protection bring their policy in line with the Alcohol Tobacco Tax and Trade Bureau to provide a 90-deferral for beer, wine and spirit importers to pay for federal excise taxes.

In the letter, the associations applauded the Administration’s recent efforts to provide financial relief to affected industries during the unprecedented outbreak of COVID-19 but requested equal tax treatment for importers.

“Importers of beer, wine, and spirits pay the same federal excise tax as domestic producers,” said the industry leaders. “We urge the Administration to revise its most recent action to provide parity between importers and domestic suppliers in terms of the ability to defer payment of the federal excise tax and extend such deferrals for consumption withdrawals through July 1, 2020.”

They underscored that the beverage alcohol industry is an important economic driver in the United States generating millions of jobs and billions of dollars in wages, taxes and employee benefits which are now more critical than ever.

The letter was signed by the Distilled Spirits Council of the United States, American Distilled Spirits Alliance, the National Association of Beverage Importers, Beer Institute, Wine & Spirits Wholesalers of America, and the Wine and Spirits Shippers Association.

NEWS RELEASE                                                                           April 3, 2020

COVID-19 Response by the State Governors Must Reflect the Critical Infrastructure and Essential Business Guidance from the Cyberinfrastructure and Security Infrastructure Agency, DHS.

As States move to "shelter in place" mandates, the Governors must decide on what is the critical infrastructure in her/his State and what are the essential businesses that facilitate and support that critical infrastructure.  Transportation of goods both within the State and between the States need uniformity in the approach here.

NABI is a member of the Critical Infrastructure Supply Chain Council (CISCC) and joined more than 80 other trade associations in sending letters to the Governors of the States that had not yet adopted these uniform positions.  The letter is below.  

* * * * * * * 

Letter to Governors

Critical Infrastructure Supply Chain Council 

April 3, 2020

Office of Governor ____________

P.O. Box 

State Capital

Governor ________:

Thank you for your leadership as we face the COVID-19 virus and its impact throughout STATE. As representatives from manufacturing, importing, distribution, supply chain, and labor, we share your desire to ensure public health and safety. Our members are working hard to provide the products, manpower, and raw materials needed during this global pandemic, which is why we need your help to protect our workforce, their families and our communities.

We are writing to you and other Governors to respectfully request your proactive leadership in providing nationally uniform recognition of core critical infrastructure. Many states already adopted this common definition, which is based on guidance developed by the DHS Cyber and Infrastructure Security Agency. As you weigh what other measures you may take in the fight against COVID-19, this step will enable the smooth flow of essential products and services within your state and across state lines required to prevent the spread of COVID-19 and maintain public health and well-being in Texas.

Specifically, to the extent you have not already done so, we request that you issue appropriate directives to:

Adopt the definition of “critical infrastructure” as defined by the Department of Homeland Security (DHS) as a floor (with additional critical infrastructure designations that the unique characteristics or needs of your state may warrant) and prohibit state and local authorities from impeding the lawful operation of business operations that supply, operate, distribute or are otherwise part of critical infrastructure.

Adopt as official state policy the guidance from the DHS Cybersecurity and Infrastructure Security Agency to identify essential critical infrastructure workers during COVID-19 response.

Ensure no COVID-19 related requirements within your state impede the lawful transportation of critical infrastructure products or movement of critical infrastructure personnel.

Establish a central authority within your state to coordinate all state and localities to facilitate understanding and smooth adoption of your COVID-19 directives.

Our members are proud to support the ongoing national response to COVID-19 and are eager to work with you. We will continue to act responsibly and limit the spread of the virus at our facilities.

We ask that those facilities, workforces and their supply chains continue to operate uninterrupted so that we may provide the strongest possible response for the American public.


Sincerely,

Adhesive and Sealant Council

Agricultural & Food Transporters Conference

Agricultural Retailers Association

American Bakers Association

American Beverage Association

American Boiler Manufacturers Association American Chemistry Council

American Cleaning Institute

American Coke and Coal Chemicals Institute

American Feed Industry Association

American Foundry Society

American Frozen Food Institute

American Fuel and Petrochemical Manufacturers

American Honey Producers Association

American Mold Builders Association

American Pet Products Association

American Seed Trade Association

American Spice Trade Association

American Sugar Alliance

American Supply Association

American Trucking Association Animal Health Institute

Appalachian Hardwood Manufacturers Association

Association for Manufacturing Technology

Beer Institute

Business Roundtable

Can Manufacturers Institute

Compressed Gas Association

Consumer Brands Association

Consumer Healthcare Products Association

Corn Refiners Association

CropLife America Decorative Hardwoods Association Distilled Spirits Council of the U.S.

EPS Industry Alliance

Flavor and Extract Manufacturers Association

Flexible Packaging Association

Food Marketing Institute

Fragrance Creators Association

Household and Commercial Products Association

Independent Lubricant Manufacturers Association

Independent Petroleum Association of America

Institute of Scrap Recycling Industries

Institute of Shortening and Edible Oils

International Bottled Water Association

International Dairy Foods Association

Livestock Marketing Association Missouri Forest Products Association National Association of Beverage Importers, Inc.

National Association of Chain Drug Stores

National Association of Chemical Distributors

National Association of Manufacturers

National Automatic Merchandising Association

National Chicken Council

National Confectioners Association

National Council of Farmer Cooperatives

National Grain and Feed Association

National Grocers Association

National Insulation Association

National Milk Producers Federation

National Oilseed Processors Association

National Pest Management Association

National Roofing Contractors Association

National Tank Truck Carriers

National Tooling and Machining Association

National Turkey Federation

National Wood Pallet & Container Association North American Building Trades Unions

North American Die Casting Association

North American Insulation Manufacturers Assoc

North American Meat Institute

North American Millers Association

North American Renderers Association

Pennsylvania Farm Bureau

Personal Care Products Council

Pet Food Institute

Pet Industry Distributors Association

Pet Industry Joint Advisory Council

Plumbing Manufacturers International

Polyisocyanurate Insulation Manufacturers

Association

Precision Machined Products Association

Precision Metalforming Association

PVC Pipe Association

Railway Tie Association

Responsible Industry for a Sound Environment

Rio Grande River Valley Sugar Growers

Single Ply Roofing Industry

SNAC International

Southern Crop Association

Structural Insulated Panel Association

Texas Citrus Mutual

Texas International Produce Association

Texas Sorghum Association

Treated Wood Council

United Fresh Produce Association

US Tire Manufacturers Association

Vinyl Siding Institute

Waterways Council, Inc

Western Hardwood Association

Wine & Spirits Wholesalers of America

Wood Component Manufacturers Association

World Pet Association

NEWS RELEASE                                                                  March 20, 2020

COVID-19 Crisis Impact on Importers

Urgency for Customs and Border Protection Refunding Claims to Importers under the Craft Beverage Modernization Act 

Importers of distilled spirits, wine, and beer have been hit hard financially by the COVID-19 crisis for reasons more than the closing of on-premise retailers, restaurants, bars, and large gathering celebratory events. Since October 18, 2019 importers of certain wines and distilled spirits from specific Members States of the European Union have paid burdensome retaliatory tariffs imposed by the United States as a result of the Airbus trade dispute at the World Trade Organization.  

Moreover, importers of distilled spirits, wine, and beer are still owed millions of dollars by CBP in refunds claims for required overpayments of the excise taxes at the time of importation since the Craft Beverage Modernization Act became effective on January 1, 2018.  Acceleration of these refund claims would provide significant liquidity to the importers as they strive to remain employees.

In a letter, dated March 20, 2020, the National Association of Beverage Importers and the Wine and Spirits Wholesalers of America urged senior CBP officials to accelerate the processing and payment of these refund claims.  

* * * * * * *

LETTER to CBP

March 20, 2020

Brenda Smith, Executive Assistant Commissioner

Office of Trade

United States Customs and Border Protection Bureau

Washington, DC

Re: Urgency of Refunds Under the Craft Beverage Modernization Act

Dear EAC Smith:

The National Association of Beverage Importers (NABI) and the Wine and Spirits Wholesalers of America (WSWA) greatly appreciate all that you and your colleagues at the Customs Border and Protection Bureau (CBP) are doing to protect the safety and security of the borders and facilitate trade in these difficult times. As we confront the challenges to our economy, we know that CBP is a partner with the trade community in strengthening our importation community so we can help build and recover our economy. It is with this goal in the forefront that we write to respectfully ask that CBP accelerate refund claims made under the Craft Beverage Modernization Act.

The Craft Beverage Modernization Act (CBMA) was enacted as part of the Tax Cuts and Jobs Act in December 2017, and extended in the Consolidated Appropriations Act, 2020. CBMA provides reduced excise tax rates and tax credits for domestic and imported distilled spirits, wine, and beer. All tiers of the beverage alcohol distribution system benefited from these tax incentives that were used to expand physical facilities, purchase equipment, and hire new employees All of these steps enhance the inventory adequacy of entire distribution chain and consumer choice. However, the importer community bears a heavier burden.

Domestic distilleries, wineries, and breweries were able to claim the reduced tax rates and tax credits immediately when CBMA became effective on January 1, 2018. Importers, however, who pay the excise taxes to CBP on these beverage alcohol products at the time of the consumption entry continued to pay the higher pre-CBMA tax rates until CBP promulgated the framework for claiming the reduced tax rates and tax credits. The framework for claiming the CBMA tax benefits was announced in October 2018. Importers are required to obtain an Assignment Certificate Letter from the Foreign Producer (each year), a Controlled Group Spreadsheet (revised as necessary), and a CBMA Spreadsheet with each entry recording the drawdown of the CBMA tax benefits assigned by the foreign producer. For many importers, this was a time-consuming effort.

During all this time, the importers were paying the higher CBMA tax rates with the understanding that CBP would process refund claims (with interest) for the overpayment of the excise taxes.

Many refund claims have been filed but many still remain unpaid. We understand that CBP Headquarters compiled a report covering the records filed by the importers and their customs brokers on these claims. That report is used by Import Specialists at the Center for Excellence and Expertise (CEE) to process the refund claims. While we understand that these claims have been difficult for CBP due to errors or incompleteness (not disclosed to us in any detail), the current economic situation counsels urgency in getting these refund payments to importers so they can keep their business solvent and operational. The telework status of the Import Specialists should not impede the processing of these refund claims.

Importers of beverage alcohol are facing unique and expanding financial challenges today in the marketplace not faced by other businesses. The retaliatory tariffs in the Airbus trade dispute, the delays in receiving refunds from CBP under the CBMA when money is desperately needed by these businesses more than ever before, and now the disruptions of the coronavirus/COVID-19 both in the supply chains of the countries they import from and in the United States in protecting and keeping safe their workers and the financial support of their families are imposing huge financial outlays by importers. At the same time, these importers are facing uncertainty in the marketplace arising from the rising likelihood of a recession.

In the current economic environment, importers need these refunds paid as quickly as possible in order to inject much needed liquidity into their business. Importers will use these monies in their businesses in ways to stimulate the economy. But we cannot do that without assistance from CBP in accelerating the processing of the refund claims. Each day the urgency becomes greater.

We are available at any time to answer any questions you may have and provide any information you may need. Thank you very much for your time on this important matter.

Sincerely,

Michelle L. Korsmo                                             Robert M. Tobiassen

President and CEO                                               President

Wine & Spirits Wholesalers of America              National Association of Beverage Importers

CC: Randy Mitchell, Director, Commercial Operations, Revenue and Entry Division at randy.mitchell@cbp.dhs.gov  

NEWS RELEASE                                                               January 13, 2020

NABI Opposes Tariffs in the USTR Review of Action in the Enforcement of U.S. WTO Rights in Large Civil Aircraft Dispute (Docket No. USTR-2019-0003)

Consistent with its strident position against tariffs, NABI voiced strong opposition to the continuation of the retaliatory tariffs on wines and distillled spirits in the Airbus trade dispute, any increase in the rate of the additional duties aka tariffs, and the addition of any further wines, distilled spirits, or beer to the retaliatory tariffs.  Tariffs are taxes on American businesses and consumers.  In the letter below, NABI articulates many of the harms to American workers, consumers, and local communities arising from these retaliatory tariffs.  

* * * * * * * 

NATIONAL ASSOCIATION OF BEVERAGE IMPORTERS I,NC.

Press Club Building, Suite 1183

Washington, DC 20045

(202) 393-6224

January 13, 2020

Submitted electronically via www.regulations.gov

Joseph Barloon

General Counsel

Office of the United States Trade Representative

600 17th street, NW

Washington, DC 20508

Re: Review of Action: Enforcement of U.S. WTO Rights in Large Civil Aircraft Dispute (Docket No. USTR-2019-0003)

Dear Mr. Barloon:

The National Association of Beverage Importers (NABI) submits this letter in response to the Federal Register Notice published on December 12, 2019 (84 Federal Register 67992) requesting comments on whether products currently subject to the 25 percent additional duty should be removed from the list or remain on the list, whether the rate of additional duty on these products should be increased up to a level of 100 percent; and whether additional products from the prior two notices from April and July 2019 should now be subject to additional duties of up to 100 percent. The Notice seeks comments on whether these additional duties are moving the EU closer to compliance with the WTO decision and whether these additional duties are resulting in a disproportionate harm to U.S. economic interests, including small and medium sized businesses and consumers.

NABI is the leading trade association, since 1935, for importers of wine, distilled spirits, and beer/malt beverages, including low and non-alcoholic malt beverages. Unique to NABI is our mandate focuses on all three categories of alcohol beverages.

NABI is part of the Joint Beverage Alcohol Coalition that submitted joint comment letters on. May 28, 2019, and August 5, 2019 in this matter that strongly objected to the inclusion of distilled spirits, wine, and non-alcoholic beer. NABI signed the joint comment letter that was submitted as part of this request for comments and this letter is an additional submission. These letters articulate why additional duties on wines and distilled spirits will create job losses in the United States, cause economic harm to importers, wholesalers, retailers and others in the hospitality industry, and increase the likelihood that the EU will impose additional retaliatory tariffs on wine and distilled spirits as part of the EU dispute with the United States relating to Boeing in United States — Measures Affecting Trade in Large Civil Aircraft (second compliant)-Resource to Article 21.5 of the DSU by the European Union and in other trade disputes with the United States, such as the Action Pursuant to Section 301: France 's Digital Services Tax (Docket No. USTR-2019-009).

We want to highlight several points that have been made repeatedly in various public submissions and testimonies given earlier in this action. All support not increasing the current 25 percent additional duty on certain wines and distilled spirits and not expanding the beverage alcohol products subject to additional duties. Rather, NABI requests that all beverage alcohol products be removed from the additional duty consideration in this action. At a minimum, the current additional duties on wines and distilled spirits should be reduced to 10 percent for parity of impact on the importer with the 10 percent additional duty on large civil aircraft.

Importers are businesses operating locally and providing jobs in their communities that indirectly support other jobs. The beverage alcohol distribution system creates many jobs from the imported products so a large portion of the retail value is generated here in the United States and not with the foreign supplier so local communities benefit from these jobs. These jobs include shippers, truckers, warehouse workers, bookkeepers and accountants, sales representatives, customs brokers, managers and others in the hospitality industry, just to name a few, that are put at risk by these additional duties currently in place and any expansion of the alcohol beverages subject to additional duties, or an increase in the rate of the additional duties. Many are solid middle-class family jobs.

As clearly evident from the testimonies at the public hearing on the Acton Pursuant 10 Section 301: France 's Digital Services Tax (Docket No, USTR-2019-009)9 there are small and medium sized import businesses that have cancelled new hiring, laid off employees and are facing potential shut-downs as a result of the current 25 percent additional duty on wines. Their stories are stories of real people facing job losses and business collapse.

Importers are working with their foreign suppliers and distributors in the United States in an effort to share the cost of the additional duties but the results have been mixed with no long-term solution. The importer is squeezed here between independent businesses and is the entity that must bear the financial burden of the additional duty at the time of the consumption entry into the United States.

Importers of all sizes face increased costs not only from the additional duties but due to the increased cost from financial institu60ns backing the upfront costs of the import shipments and the increased costs of larger customs bond coverage.

Additional duties of 25 percent are not sustainable for many importers whose brand portfolio are primarily ones covered by the current additional duties. If raised to 100 percent there would be widespread closures. The Government should not be picking winners and losers in the domestic marketplace by these additional duties.

In the case of premium wines with limited allocations, some importers are facing foreign producers who are shifting those allocations to countries in Asia and elsewhere to avoid the uncertainty of the United States market. These are hurting business relationship that took many years, if not decades, to develop.

Other wines and distilled spirits are losing market share as a result of the price increases arising from the additional duties. Brands have different price sensitivities. For some brands, the additional duty results in a consumer perception that the product is "overpriced." Market share once lost is very difficult to recover once the additional duties are ended.

This WTO dispute involves large civil aircraft and not the beverage alcohol industry. The additional duties should focus on the civil aircraft and aeronautical parts and equipment, The 10 percent additional duty on civil aircraft means that the purchaser of a $200 million aircraft would pay $20 million whereas the 25 percent tariff on the importer of wine or distilled spirits currently covered by the additional duties would pay $50 million on the importation of $200 million of wine and distilled spirits, that is, two and one half times more. Simply put, this results in a disproportionate harm to beverage alcohol products covered by the additional duties.

Nonalcoholic Beer

In this request for comments, USTR asks whether products from the prior two lists not subject to current additional duties should be now be subject to additional duties. Nonalcohol beer (HTS subheading 220291.00) appears on the proposed lists. Nonalcoholic beer is not discussed in detail in the Joint Beverage Alcohol Coalition letters. Because NABI has beer and malt beverages within its mandate, we are providing comments on why nonalcoholic beer should not now be subject to additional duties.

First, the imposition of additional duties on nonalcohol beer would not move the EU closer to compliance with the WTO decision. In 2018, all nonalcoholic beer (foreign and domestic) accounted for just 0.3 percent of the off-premise sales (grocery, liquor and convenience stores) in the United States. Even ifth1S market share is increasing as many consumers are moving to lower-alcohol content products, the import volume is not sufficient enough to where the additional duty would push the EU to move more quickly on a negotiation.

Second, the imposition of an additional duty on nonalcoholic beer would result in a disproportionate harm to consumers in the United States The Federal government through the Department of Health and Human Services (HHS), National Institute on Alcoholism and Alcohol Abuse (NIAAA), National Institute of Health (NIH), and the Dietary Guidelines for Americans, among others, has a strong public health policy of promoting responsible and moderate consumption of alcohol beverages by those consumers who decide to drink in the first instance.

Nonalcoholic beers directly advance and support this vital public health policy, Additional duties making access to these nonalcoholic beers more expensive undercuts the promotion of this sound public health policy.

The arguments stated above are consistent with those stated in the enclosed letter, dated June I I, 2019, from several Members of Congress encouraging USTR to remove nonalcoholic beer from list of EU products that might subject to additional duties.

NABI appreciates this opportunity to comment. Please do not hesitate to contact me should you require further information.

Sincerely,

Robert M. Tobiassen

NABI President

Enclosure


Joint Statement by NABI and Other Alcohol Beverage Trade Associations Opposing Tariffs

For Immediate Release:                                                                              

August 5, 2019                                                                                                                                                                                   

 

U.S. Retaliatory Tariffs Could Cost up to 78,600 Jobs in U.S. Beverage Alcohol & Hospitality Sectors

 

Alcohol Trade Groups Urge USTR Not to Impose Retaliatory Tariffs on EU Spirits & Wines

 

WASHINGTON, DC – Up to 78,600 jobs in the U.S. beverage alcohol and hospitality sectors could be lost if distilled spirits, wine and non-alcoholic beer are included on the final U.S. list of European Union (EU) products targeted for retaliatory tariffs, according to an analysis in a submission to the United States Trade Representative (USTR) by U.S. alcohol trade groups.

 

The proposed retaliatory tariff list is part of a long-standing dispute at the World Trade Organization (WTO) regarding civil aircraft subsidies and is unrelated to the beverage alcohol industry.

 

The joint comment was submitted by U.S. alcohol trade groups representing several beverage alcohol suppliers, wholesalers, importers and retailers.  In the submission, the groups reaffirmed their strong objection to tariffs and the inclusion of EU spirits and wines on the preliminary retaliation list emphasizing that it “will lead to negative unintended consequences for U.S. consumers, will cause a further decline in U.S. beverage alcohol exports and will result in a significant loss of U.S. jobs.” 

 

They explained that imposing retaliatory tariffs on EU wine and spirits products harms both the U.S. and EU alcohol sectors since many companies have created complementary product portfolios comprised of both domestic and imported spirits, wine and beer brands to meet consumer demand. 

 

According to the analysis, approximately 11,200 to 78,600 U.S. jobs could be eliminated if the U.S. moves forward in slapping tariffs on spirits and wine products imported from the EU.  This estimate is a significant increase from the loss of jobs estimated in the group’s May 28th submission due to USTR’s decision to add Scotch Whisky and Irish Whiskey to its April 8 preliminary list of EU products, which included wine, liqueurs and cordials, and Cognac.

 

“If beverage alcohol products remain on the final U.S. list, the EU would certainly respond by keeping U.S. beverage alcohol products on its list, thus inflicting more damage on U.S. companies that export to this critically important market and hampering the export progress that has benefited our sectors and created good paying jobs across the U.S,” the groups stated. The EU has threatened to impose tariffs on imports of U.S. wine, vodka, and rum.

 

The groups underscored that the impacts of retaliatory tariffs are accelerating and are being felt across the entire U.S. supply chain, from farmers to suppliers to retailers.

 

-more-

 

 

 

Since the EU’s imposition of a 25 percent tariff on American Whiskey last summer, American Whiskey exports have declined 19 percent.  Additionally, China is imposing a 54 percent retaliatory tariff on U.S. wine imports, which is contributing to a 57 percent decline in trade with China since the beginning of 2019.

 

Several small U.S. distillers and vintners have had their export orders cancelled due to the tariffs and as a result have put a hold on hiring and have cut back on grain purchases.

 

The joint comment was submitted by the Distilled Spirits Council of the United States, American Craft Spirits Association, American Distilled Spirits Association, Kentucky Distillers’ Association, Wine Institute, WineAmerica, Wine & Spirits Wholesalers of America, Wine and Spirits Shippers Association, American Beverage Licensees and the National Association of Beverage Importers.

 

The full text of the public comment can be downloaded here.

 

DISCUS and NABI Presidents Testify at USTR Hearing on Retaliatory Tariffs

 

In addition to the joint submission to USTR, the presidents of the Distilled Spirits Council of the United States and National Association of Beverage Importers are testifying today at a related hearing at USTR.

 

Distilled Spirits Council of the United States President and CEO Chris Swonger’s testimony can be downloaded here.

 

National Association of Beverage Importers President Robert M. Tobiassen’s testimony can be downloaded here.

 



FOR IMMEDIATE RELEASE                      (NABI Press Release No. 2019-6)       

National Association of Beverage Importers, Inc.  

Washington, DC                                                                               

July 9, 2019

 NABI Highlights Label Proposals to TTB Rulemaking   

The National Association of Beverage Importers, Inc. (NABI) put forth a number of key revisions to the proposed labeling and advertising regulations last week in its comment letter to TTB that would greatly enhance the alcohol importation industry without undermining the important consumer protection purpose of the Federal Alcohol Administration Act of 1935.   

Specifically,   

Adopting a Notice to TTB approach in lieu of the present application approval approach for COLA Waivers.  Importers would simply notify TTB of samples coming in for trade shows or sales promotions and affix the standard strip label stating the restricted nature of the bottled product.  Delay times awaiting approval and staff resource time by TTB would be gone and these imports would not be interrupted by any lapse in appropriations.  Targeted post-audit reviews by TTB would prevent abuse of this Notice approach.

 Since enactment of the labeling provisions in 1935, the “commercial speech doctrine” under the First Amendment has significantly changed how a Federal agency may restrict truthful and accurate information on labels so the NABI comments point out ways that the “misleading” standard may be applied more transparently in label approval reviews.   

Today’s consumer is more sophisticated than the dry-consumer coming out of Prohibition who perhaps needed greater government protection so the 21st Century labeling and advertising regulations need not be as comprehensive.  Moreover, the younger generation of consumers use I-phone and online research for immediate information about the brands of alcohol beverages they are consider purchasing.  Self-policing of label claims by consumers is greater today and the “brand death” from a misleading claim going viral on social media is a more effective deterrent than many government regulations.     

Private labels and controlled labels are claiming more and more of the retail market space and the labeling regulations need to include provisions recognizing the ways to inform consumers about these brands.  Additional NPRM notice and comment opportunity is needed here.   

Global trade is bringing new distinctive products to consumers in the United States.  The regulations must include an administrative process to provide formal recognition to these distinctive products from other countries so that consumers may purchase with certainty the authentic product.   

The “approximately 50-gallon barrel” standard is unworkable for imported products.  Production practices in other countries cannot be expected to conform to a United States requirement like this one, nor can importers be expected to police this type of production requirement on the bottled alcohol beverages they import.   

Mandatory Certificate of Label Approvals (COLAs) retention by importers should not be required because the approved COLAs are always available online with TTB so this is an unnecessary and duplicative burden on the industry.  Optional retention by the importer should be the norm.   

The new regulations on “Substantiation Requirements” must be clarified and narrowed to inform adequately the industry member of the requirements.  The proposed regulations impose a new requirement for importers (and domestic bottlers) to provide upon demand from TTB “evidence” sufficient to substantiate “any claim made on any label or container subject to the requirements of this part.”  A claim may be “implicit or explicit.”  As worded, this provision is far too vague under due process requirements of informing the industry member of its obligations.  What might be an implicit claim is too open ended for an importer to know what informational evidence it must maintain for five years.  In light of the huge numbers of different brands and SKUs entering the United States marketplace each year, this regulatory burden is enormous, unlimited in scope, and unmanageable.  “Due process” requires far more clarity than what is in these proposed sections.   

NABI greatly appreciates the NPRM by TTB and sees this as an important opportunity to reduce regulatory burdens and adopt new, creative, and innovative approaches to labeling and advertising regulation reflective of the mature consumers and the sophisticated industry business models.  TTB has a great opportunity here to move some proposals quickly to final regulations and in the near future re-notice those proposals from the comments that may require further notice and comment opportunity under the Administrative Procedures Act before moving to a final regulation.  We commend TTB in advance for consideration of such a two-step approach.   

NABI’s extensive comment letter is available as Comment No. 984, at:  

https://www.regulations.gov/document?D=TTB-2018-0007-0987   

For further information, please contact

Robert M. Tobiassen, NABI President, or 

Bernadeen Emamali, NABI Vice-President and Corporate Secretary 

at: (202) 393-6224                                                         www.bevimporters.org  



FOR IMMEDIATE RELEASE                     (NABI Press Release No. 2019-5)      

National Association of Beverage Importers, Inc.

Washington, DC                                                                               

May 30, 2019 

NABI Opposes Taxing Happiness and Responsible Drinking.  Don’t You?   

Tariffs are taxes.   Paid by importers at the time of the entry of these products, these monies fill the Treasury coffers in the identical manner as do taxes.  But then these financial impositions on imported distilled spirits, wines, and beers are borne by consumers.    

The United States has proposed retaliatory tariffs against European Union (EU) products as a result of the World Trade Organization (WTO) decision that the EU gave improper subsidies to Airbus that, in turn, harmed Boeing from a competitive disadvantage point of view.  In addition to tariffs aeronautical parts (which are at the heart of the dispute), the proposed retaliatory tariffs include grape wines from the EU, grape-based distilled spirits, liqueurs and cordials, and nonalcoholic beers.   

NABI President Robert M. Tobiassen said “the wide range of imported alcohol beverages available to consumers reflect their demand for these products.  The United States is a hugely consumer driven economy and retailers offer products that consumers want for their pleasure and enjoyment.”  For fiscal year 2018, TTB approved 185,072 certificates of label approval (COLAs) of which 86,958 represented domestic products and 98,114 represented imported products. Consumers want these unique products and are demanding them.   Tobiassen asks “Why tax their happiness?”    

Earlier this month, at a public hearing in Washington, DC on the proposed tariffs, trade officials suggested that they view many of the goods and commodities on these proposed tariff lists as fungible or generic in nature.  That is, red wine is a red wine or a liqueur is a liqueur.  This assumption fails to recognize the fact that consumers of alcohol beverages have very subjective tastes and loyalties to specific types of these beverages.  Visit any bar or pub and many, many customers order their alcohol beverages by brand or place of origin.  A red Burgundy/Bourgogne is not an American Pinot Noir to them, nor is a white Burgundy/Bourgogne an American chardonay to these wine consumers.  Flavors, taste characterisitcs, and aromas between wines are all distinctive to these consumers.  Why should they be penalized to pay more for these wines they enjoy.  These consumer preferences are equally held by consumers in distilled spirits and non-alcoholic beers as well.  Grappa consumer want their grappa from Italy as do Cognac consumers want their product from France.   

Moreover, the public is turning to more low alcohol or nonalcoholic beverages.  Importation of nonalcoholic beers enable retailers to meet this consumer demand, as well as advance public health and safety policies.  The Federal government through the Department of Health and Human Services (HHS), National Institute on Alcoholism and Alcohol Abuse (NIAAA), National Institute of Health (NIH), and the Dietary Guidelines for Americans, among others, has a strong public health policy of promoting responsible and moderate consumption of alcohol beverages by those consumers who decide to drink in the first instance.  Nonalcoholic beers directly advance and support this vital public health policy.  Retaliatory tariffs making access to these nonalcoholic beers harder undercuts the promotion of this sound public health policy.   

Similarly, sound public welfare policies are advanced here too in regards to preventing automobile deaths by drunk drivers.  Designated drivers may safely consume nonalcoholic beers as part of their friends’ social gatherings.   

This is a dispute over large civil aircraft.  Other than being served on airplanes, alcohol beverages have no nexus to aircraft.  Sufficient tariffs imposed on aeronautical parts will compensate the United States and deal directly with negating the competitive advantages from the improper EU subsidies.   

Don’t tax consumers’ happiness; don’t undercut sounds public policies on responsible consumption.   

For further information, please contact 

Robert M. Tobiassen, NABI President, or 

Bernadeen Emamali, NABI Vice-President and Corporate Secretary 

at: (202) 393-6224                                                         www.bevimporters.org



NABI Elects New Chairman of the Board

NABI Elects New Chairman of the Board and Explores the Opportunities and Challenges of the 21st Century Global Market at its 84th Annual Meeting 2019 
 
Gabriel Bisio, General Counsel and Chief Compliance Officer of Palm Bay International was elected as Chairman of the Board at the 84th Annual Meeting of the National Association of Beverage Importers (NABC) in New York City.  NABI President Robert Tobiassen said “We are pleased and fortunate to have Gabe as our Chairman for the next two years as he brings more than 15 years of alcohol beverage industry experience from his work with the Taub Family Company and before that Diageo North America.  Gabe, an attorney with a vast international experience understands both the challenges of family and global companies, along with the diversity of the New World producers of wine, distilled spirits, and beers, and Old World traditions.”  
 
Gabe follows Chairman Justin Kissinger now Director, Global Public Policy, HEINEKEN N.V., who commenced his NABI service when he was at HEINEKEN USA.  The Board expressed its gratitude to Justin for his dedication.  
 
NABI members at the annual meeting and working lunch focused on the three elements of our Strategic Goal and Plan for 2019 and Forward of (1) delivering business services to members grounded in our presence in Washington, DC with person-to-person contacts, (2) being a key information source for members of new regulatory developments and up to date market trends, and (3) networking with domestic associations and international organizations focused on streamlining trade and modernization regulatory regimes.  
 
In helping to set the stage for the strategic goal discussion, NABI had the great benefit of insights from Susan Evans, Director, TTB Office of Industry and State Relations on where TTB is going and from Bobby Conroy, Wine Director, The Clock Tower, NYC, Court of Master Sommeliers, who helped us understand the dining consumer alcohol beverage selection experiences.  For without an understanding of the consumer demand pulling imported products through the distribution system, there would be no imports.  
 
NABI is the leading trade association for importers of distilled spirits, wine, beer, and low and non-alcoholic beverages in the United States.  Established in 1935, in the wake of the Repeal of Prohibition, NABI has aided its members for eight decades in importing the widest range of products for American consumers to enjoy in a responsible manner.  Recently, NABI has been the strong advocate for the import provisions of the Craft Beverage Modernization Act (CBMA) and worked closely with Customs and Border Protection on its implementation.  Ease of administration and protection of the tax revenue are the guideposts of NABI’s efforts on CBMA.  Today, there are more than 12,000 importer basic permits issued by the Alcohol and Tobacco Tax and Trade Bureau providing solid, wellpaying jobs in every State and jobs that cannot be shipped overseas.  “Delivering a WORLD of taste to AMERICA” is the NABI moto and goal.  

FOR IMMEDIATE RELEASE                     (NABI Press Release No. 2019-3)     

National Association of Beverage Importers, Inc.  

Washington, DC                                                                               

May 15, 2019   

NABI Testifies Against Retaliatory Tariffs on Imported Wines, Distilled Spirits, and Non-alcoholic Beers in USTR Hearing   

Today, the National Association of Beverage Importers, Inc. (NABI) testified at the Section 301 Committee of the United States Trade Representative (USTR) in Washington, DC against the proposed retaliatory tariffs on imported grape wines (regardless of alcohol content or effervescence) non-alcoholic beers, liqueurs and cordials, and grape derived distilled spirits (that is, brandy).   

NABI President Robert M. Tobiassen stressed that the retaliatory tariffs should be limited to aeronautics equipment because that is the underlying trade dispute.  Airbus operations in the United States import parts and equipment from the EU to assembly its aircraft here and those goods should bear the entire tariff burden in order to compel the EU to cease the wrongful subsidies to Airbus.  This directly attacks the unjustified competitive harm to Boeing.   If other goods are covered by retaliatory tariffs, then they should do the least damage to the interests of American consumers, industries, economy, and Federal Government public policies.   

NABI President Tobiassen said “the Federal Government should speak with one voice and not impose retaliatory tariffs that undercut other Federal public policies.”  Imported alcohol beverages raised significant excise tax revenues for the Treasury and nothing in trade policy should undercut that sound fiscal policy. The Department of Health and Human Services along with the National Institute of Alcoholism and Alcohol Abuse has a strong public health policy on moderate consumption which is advanced by non-alcoholic beers.  Non-alcoholic beers allow consumers to join with their friends in social settings and have a range of social beverages without alcohol available for their enjoyment.  The Department of Transportation has drunk driving prevention public policies that are advanced by designated drivers consuming non-alcoholic beers.   

The wide range and brand diversity of imported distilled spirits and wine shows that consumers see many of these imported products as having unique characteristics not available to them in domestic alcohol beverage products.  For fiscal year 2018, TTB approved 185,072 certificates of label approval (COLAs) of which 86,958 represented domestic products and 98,114 represented imported products. Consumers want these unique products and are demanding them.    

Imported distilled spirits and wines and domestic distilled spirits and wines are not necessarily interchangeable and fungible in all brand cases.  This is not true of many other goods and commodities on the retaliation tariff list.  There is no sound policy reason to deny American consumers access to these unique and different imported products not otherwise available to them with a domestic counterpart or from a country other than an EU Member States.  Nor should they have to pay higher prices for their preferred tipple.  Consumers hold personal preferences that are subjective and deserve to be respected by trade negotiators.  Tariffs on these products are essentially taxes on happiness.   

NABI joined 48 trade associations and businesses testifying on all aspects of the proposed tariffs and was the only alcohol beverage association to present oral testimony.  Final written comments are due by May 28, 2019.  NABI is preparing additional comments and is working with DISCUS and other trade associations on a common approach to oppose these tariffs.   

The Section 301 Committee is chaired by USTR and has members from the Treasury Department, State Department, Department of Agriculture, Small Business Administration, Department of Transportation, Department of Commerce, and Department of Labor.  After all of the testimonies and comments are received on May 28th, the Section 301 Committee will prepare a final retaliatory tariff list with percentages of the rates of the retaliatory tariffs.   

For further information, please contact 

Robert M. Tobiassen, NABI President, or 

Bernadeen Emamali, NABI Vice-President and Corporate Secretary 

at: (202) 393-6224      

www.bevimporters.org



Welcome to Giorgio Gori USA, Inc. As newest NABI Associate Member

Giorgio Gori USA, Inc. is primarily involved in freight services and in related aspects and functions with wine and spirits logistics specialists.  Giorgio Gori USA operates in New Jersey.



FOR IMMEDIATE RELEASE                     (NABI Press Release No. 2019-4)   

National Association of Beverage Importers, Inc.  

Washington, DC                                                                               

May 27, 2019   

NABI Mourns the Passing of TTB Administrator John J. Manfreda – A Visionary and A Friend   

NABI extends its deepest sympathy to John’s wife Rosemary, his children Michelle, Matthew, and Brendan and their families in this sad time of loss.    

NABI President Robert M. Tobiassen prepared the remarks below.  From 1978 to 2003, at ATF, John was Rob’s first- or second-line supervisor and always his mentor.  John encouraged Rob to follow John in earning a Masters in Tax Law from Georgetown University Law School and develop a keen interest in alcohol and tobacco taxation, regulation, and compliance controls.  From 2003 to 2012, John was one of Rob’s principal program clients at TTB in his role as TTB Chief Counsel.   

We are All the Lesser   

“Magnanimity in politics is not seldom the truest wisdom.”  Edmund Burke 1720-1797

 John Joseph Manfreda was a gracious gentleman, wise mentor, fierce and yet fair challenger, and a truly magnanimous person.  He will be missed.   

There are so many stories to tell about John it is hard to know where to start.   

He was proud that he was a native of the DC metropolitan area. If my memory has not failed. I believe that he first saw Rosemary when he was working part-time in the butcher section of a grocery store and she walked by and he cut himself on the meat cutter.  He knew that she was the woman to be his wife.    

John understood work-life balance before it was trendy.  His coaching of local basketball teams and his devotion to family were always there.  His handyman skills helped to renovate houses for family members and he would wait for Rosemary to leave the house before he did crazy work like taking down really tall trees in his backyard.  Family was so important to John and he enjoyed the benefit unknown to so many in our contemporary time of having all three of his children and their families live close by.   

John could joke and flirt and prankster in the office.  Yet he had the highest expectation of professionalism and hard work by all who worked under him.  He subscribed to Chief Counsel Marvin Dessler’s approach that you had to be thorough and get it right.  He would think outside the box but you better first show him you knew the box.  You researched back to 1935 for the FAA Act and back to the Civil War, if not earlier, for the IRC.   

John knew the difference between personal and professional.  You could have a “down and dirty” discussion on legal matters and five minutes later be talking about your families.  The line between the two was respected and not crossed.   

His professionalism was unmatched.  Many of you know John’s distasteful view of the Section 5010 credit following his seminal legislative project on All-in Bond.  Yet he treated with respect the lobbyist who got this enacted.  Similarly, with the small producer wine credit, he was respectful in later meetings, though in all of these situations he would have one of us sit in on the meetings as a witness to the discussions.     

For 24 years, I had the benefit of John as my boss and mentor in Counsel’s office.  In 2003, we both woke up one morning to different jobs.  He as Deputy Administrator and me as Chief Counsel.  In moving to the program side of the bureau from the Counsel side, the bureau greatly benefited from his wisdom and guidance.  For me, he respected my role as essentially successor Chief Counsel to him.  Yet I always knew in advisory meetings with him, the bar on my legal advice was high because he had been the experienced Chief Counsel.   

His love and dedication and worry about the future of TTB, I believe kept him in his job as Administrator longer than most others would have stayed.  John came from and understood a Washington, DC that worked better.  His dedication may well have had its toll on him.   

John was a humble and dutiful Roman Catholic.  May God grant him eternal peace and I know that the Lord is saying “well done my good and faithful servant.”   

May those of us who gather next month in Louisville for the NCSLA conference or elsewhere toast him.  His favorite bourbon was Blanton’s (Mark Brown did not pay me to say that) so let us all raise the glass to him.   

John, you are missed.   

No man is an island entirely of himself.  He is piece of the continent, a part of the main.  If a clod of dirt be washed away by the sea, Europe is the less as well as if a promontory were.  Every man’s death diminishes me because I am involved in mankind.  Thus, never send to know for whom the bell tolls, it tolls for thee.

The Rev. John Donne.  1572 – 1631    

For further information, please contact 

Robert M. Tobiassen, NABI President, or 

Bernadeen Emamali, NABI Vice-President and Corporate Secretary 

at: (202) 393-6224      

www.bevimporters.org



FOR IMMEDIATE RELEASE                     (NABI Press Release No. 2019-2)     

 

National Association of Beverage Importers, Inc.

Washington, DC                                                                               

May 8, 2019

 

 

“Delivering a WORLD of Taste to AMERICA” Continues to Be the Right Thing to Do to Enhance Consumer Choices 

 

Consumer driven choice has been the linchpin of alcohol competition law by Federal and State Governments since the Repeal of Prohibition.  Brands of alcohol beverages on the shelves of “brick and mortar” retail premises, pubs on corners or in malls, restaurant wine lists, and on-line product choice delivered through e-commerce enables consumers to demand and receive what they want rather than receive what the industry believes they should want.  We have a consumer “pull” system and not an industry member “push” system for brand available to consumers.  This is why the recent statements CEO Rick Tigner of the Jackson Family Wines before a meeting of local business and community leaders in Santa Rosa calling for trade barrier protections for domestic wines is surprising and more so troubling.[1]  Ultimately and appropriately, consumer preference dictates the brands offered in the United States marketplace. 

 

NABI President Robert M. Tobiassen said “Without a doubt, consumer choice is unbelievably enhanced by imported distilled spirits, wine, and beer.  Consumers experience the world from the comfort of their homes and favorite drinking establishments.  From the design of labels and bottles to consumer tastings/ samplings at retail establishments, and consumer advertising specialties for take away by the consumer at retail establishments, the brands and varieties of imported distilled spirits, wine, beer educate us about the world.   Pure authenticity telling consumers the story of their drinks.” 

 

More than 12,000 importer basic permit holders from TTB source almost a hundred thousand of brand names for American consumers and their enjoyment.  Trade enhances consumer choice in the United States which is the largest consumer driven marketplace in the world. 

 

Rather than discourage consumers from enjoying imported distilled spirits, wine, and beer, the domestic wineries should up their efforts on exports and enhance its promotional activities to attract consumers.  Creating an artificial and anti-consumer choice domestic demand by restraining imported products is not the answer.  No one wins from the current saber rattling over tariffs by both the United States and European Union.  Global trade benefits all—consumers. growers of grapes, hops and grains, producers, exporters, importers, distributors, and retailers.  It enhances peace and prosperity as was envisioned in the Post-World War II international model of a global trading order.[2] 

 

Mr. Tigner argues that other countries impose tariffs or duties hurting American wines entering those markets so the United States is justified in imposing the same on imported wines.  Why should American consumers pay more for other countries’ bad decisions?  In the United States, we fight these foreign market trade barriers by working to remove them and not by adopting them.   

 

Consumers demand for the availability of imported distilled spirits, wine, and beer is indisputable.   For fiscal year 2018, TTB approved 185,072 certificate of label approvals (COLAs) of which 86,958 represented domestic products and 98,114 represented imported products.  Consumer “pull” in the marketplace caused this.  Clearly consumers are looking for the diversity and variety of imported products to enjoy.  No tariff or non-tariff trade barrier should be erected by the domestic industry to tell consumers that they cannot have what they want at the most competitive pricing.      

 

A rising tide raises all ships—both imports and domestics.  Consumers sail better on this tide of brand choice, variety, and opportunity to experience the enormous diversity of distilled spirits, wine, and beer from both fine American producers and world producers.  Consumers deserve nothing less.   

 

* * * * * * *

 

NABI is the leading trade association for importers of distilled spirits, wine, beer, and low and non-alcoholic beverages in the United States.  Established in 1935, in the wake of the Repeal of Prohibition, NABI has aided its members for eight decades in importing the widest range of products for American consumers to enjoy in a responsible manner.  Recently, NABI has been the strong advocate for the import provisions of the Craft Beverage Modernization Act (CBMA) and worked closely with US Customs and Border Protection (CBP) on its implementation.  Ease of administration and protection of the tax revenue are the guideposts of NABI’s efforts on CBMA.  Importer basic permit holders are providing solid, well-paying jobs in every State and jobs that cannot be shipped overseas.  “Delivering a WORLD of taste to AMERICA” is the NABI moto and goal.    

 

For further information, please contact:

 

Robert M. Tobiassen, NABI President, or

Bernadeen Emamali, NABI Vice-President and Corporate Secretary

at: (202) 393-6224        

 

www.bevimporters.org



[1] https://www.northbaybusinessjournal.com/industrynews/wineindustry/9556660-181/jackson-family-wines-ceo-calls

[2] John H. Jackson, The World Trade Organization, Constitution and Jurisprudence (Chatham House Papers 1998).