TTB Suspends Multiple Permits for Consignment Sales

Last week, TTB reported that the agency suspended six (6) alcohol beverage permits between December 2018 and January 2019 for violations of consignment sale provisions of the Federal Alcohol Administration Act. Four wine wholesalers and two wineries faced a one-day stipulated permit suspension; a fifth wholesaler who was under investigation opted to surrender its permit. As reported by TTB, the suspensions and surrender resulted from investigations through a joint effort with the California Department of Alcoholic Beverage Control in March 2018. Some more details can be found here. Consignment sales are illegal at the federal level; engagement in consignment sales can also be illegal at the state level. Federally, 27 CFR § 11.21 states that it is unlawful for an industry member to “sell, offer for sale, or contract to sell to any trade buyer, or for any such trade buyer to purchase, offer to purchase, or contract to purchase any products a) on…

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