The cost of entering a market includes administrative steps as well as the goods themselves. TTB's December 22, 2016 final rule changed one such step: covered importers could submit relevant TTB information electronically rather than through the corresponding paper documents when filing customs entry or entry-summary data electronically. The mechanism was an option, not compulsory duplication of both routes. [2016-29201][2016-14359]

The June 21 proposal showed why that option should not be confused with removal of an entry requirement. It proposed using a basic-permit number in the electronic filing to demonstrate the underlying authorization. Final section 1.58 retained that requirement for covered alcohol imports and kept the permit available for inspection on request. A different transmission method did not eliminate the need to hold the permit. [2016-29201][2016-14359]

Records remained another part of the cost structure. For distilled spirits imported in bottles, final section 5.52(f) required copies of specified certificates for five years after removal from customs custody, available to TTB or customs on request. That narrow example prevents a misleading inference that digital submission makes supporting documentation disappear. It does not establish a five-year period for every alcohol or tobacco record. [2016-29201][2016-14359]

The original rule specified December 31, 2016 as its effective date. An optional electronic route could change firms' filing choices, but the sources do not measure lower transaction costs, faster clearance or easier competitive entry. Proposal and final rule are one evidentiary chain. The market question is which administrative step changes while the permit and recordkeeping obligations remain, not whether digitization automatically makes trade inexpensive. [2016-29201][2016-14359]

Source documents

  1. Amendments To Streamline Importation of Distilled Spirits, Wine, Beer, Malt Beverages, Tobacco Products, Processed Tobacco, and Cigarette Papers and Tubes and Facilitate Use of the International Trade Data Systemhttps://www.govinfo.gov/content/pkg/FR-2016-12-22/html/2016-29201.htm
  2. Amendments To Streamline Importation of Distilled Spirits, Wine, Beer, Malt Beverages, Tobacco Products, Processed Tobacco, and Cigarette Papers and Tubes, and Facilitate Use of the International Trade Data Systemhttps://www.govinfo.gov/content/pkg/FR-2016-06-21/html/2016-14359.htm