Date of Award
Doctor of Philosophy
Labeling of malt beverages is impacted by multiple entities, both regulatory and industry. The entity with the most overt impact is the Alcohol and Tobacco Tax and Trade Bureau (TTB), which defines and regulates the following items: 1) required label components for beverages that meet the TTB’s institutional definition of “malt beverage”, and 2) the formula approval process for malt beverages required to undergo the pre-Certificate of Labeling Approval (COLA) evaluation. In order for producers of malt beverages to sell their products in interstate commerce, they must first satisfactorily complete the Certificate of Labeling Approval (COLA) process. For products that are created using “nontraditional” processes or ingredients, producers must also complete a formula submission prior to completing the COLA process. The substantial growth of the craft brewing industry has resulted in a corresponding increase in the submission volume of COLAs and formula approvals. The increased workload of TTB officials responsible for processing approvals, coupled with intense industry focus on innovation, has resulted in a complicated interchange between industry and government. Using three studies, this research evaluates the craft brewer experience with the TTB’s COLA and formula approval processes.The first study was a qualitative research study conducted to explore craft brewers’ perceptions of regulations related to the COLA and formula approval processes. Using convenience sampling, 13 interviews were conducted with craft brewers from August 2018 to December 2018. All interviews were conducted using a semi-structured interview guide and analyzed using a thematic approach. The findings indicate that formula and labeling approval presents unique challenges to craft brewers. Participants associated with small and large craft breweries identified opportunities for improved communication between the craft brewing industry and the TTB. The data collected also indicate that that there exist opportunities to improve existing resources for brewers as they pertain to labeling and formula approval.The second study evaluated the role of brewery characteristics in brewer preparation of COLA and formula submissions. Using survey data, the relationship between brewery characteristics and regulatory submission outcomes was evaluated. The brewery characteristics of interest were number of full-time personnel, permit age, production volume, and COLA and formula submission volume. The submission outcomes evaluated were information burden, expense burden, and resubmission frequency of COLA and formula approvals. The results indicated that production volume significantly predicts one measure of information burden (regulatory navigation) related to COLA preparation: the data suggests that as production volume increases, information burden decreases. In addition, submission volume of formulas was significantly related to one measure of information burden (regulatory navigation), with decreased information burden occurring alongside increased submission volume. Expense burden and resubmission frequency were not significantly predicted using any of the studied brewery characteristics.The third study examined the role of resource utilization in regulatory submission outcomes (expense burden, information burden, resubmission frequency). Using survey data, the relationship between the volume and type(s) of resources used during submission preparation and submission outcomes was evaluated. The resources of interest were: the TTB website, the Brewers Association website, advice from a fellow brewer, advice from a coworker or boss, correspondence with TTB officials, and (in formula submissions) the TTB Exemption List (Attachment 1 of TTB Ruling 2015-1) .The results indicate that advice from a boss or coworker reduced expense burden of COLA submissions, while advice from a fellow brewer was associated with decreased expense burden of formula submissions. In addition, advice from a fellow brewer, correspondence with TTB officials, and use of the Brewers Association website were all associated with decreased information burden of COLA submissions. Information burden associated with formula submissions was significantly predicted using advice from a fellow brewer and advice from a boss and/or coworker. Resubmission frequency of formula submissions was significantly predicted using correspondence TTB officials.
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