Next to regular hand washing with soap for 20 seconds, ethanol-based hand sanitizers are an effective way to reduce the spread of the COVID-19 virus, but hand sanitizers have been in short supply. Guidance issued March 18 by the federal Alcohol Tax and Trade Bureau (TTB) now allows existing distilled spirits permittees to begin immediate production of hand sanitizer or distilled spirits (ethanol) for use in hand sanitizers without having to obtain TTB’s authorization.
Ordinarily, a distilled spirit permittee would have to obtain additional permits or bonds to manufacture hand sanitizer or supply ethanol for use in the manufacture of hand sanitizer. The TTB guidance now exempts alcohol fuel plants and beverage distilled spirits plants from that requirement, provided they continue to keep records of their operations, including any undertaken as authorized under the exemption.
The guidance also does the following:
- Allows alcohol fuel plants and beverage distilled spirits plants to manufacture without first obtaining formula approval from TTB hand sanitizer products that are comprised of:
- Denatured or undenatured ethanol;
- Glycerol (not less than 1.45 percent of the finished hand sanitizer product on a volume basis); and
- Hydrogen peroxide (not less than 0.125 percent of the finished hand sanitizer product on a volume basis).
- Exempts hand sanitizer products from federal excise tax if made with denatured ethanol, but undenatured ethanol still is subject to federal exercise tax.
- Requires manufacturers of hand sanitizer products to follow World Health Organization (WHO) guidance.
- Allows industrial alcohol users to use denatured ethanol to manufacture hand sanitizer consistent with WHO guidance without first obtaining formula approval.
These exemptions are to remain in place at least through June 30, but may be extended as necessary.