Title:
Comment 46: National Association of Beverage Importers, Inc. (Earle, William T.)

Abstract:
NABI is not recommending rulemaking to define terms beyond “estate bottled.” Should TTB decide to move forward with a notice of proposed rulemaking for terms listed in notice 109, NABI will actively contribute to the comment record. Rules that impact terms already in wide use by basic permit holders should also include grandfathering provisions.