The Alcohol and Tobacco Tax and Trade Bureau (TTB) has published a new circular which updates the TTB’s alcohol advertising regulations relating to alcohol beverage advertising on various forms of social media.
As background, The TTB requires that all alcohol advertisements, including those posted to social media, provide consumers with adequate product information, identify the person responsible for the advertisement, and contain certain mandatory disclosures. On a website, these disclosures must appear in a readily apparent location. However, some forms of media, like social networks and media sharing sites, limit the space available for mandatory information. It is important for all alcohol producers who use digital marketing understand the details of the regulations.
TTB Industry Circular 2024-1 now allows alcohol advertisers on social media to use links to satisfy mandatory advertising information requirements. In other words, brewers and other alcohol beverage producers are allowed to meet the mandatory disclosure requirements by linking directly to a separate page that contains the mandatory information.
Additionally, Industry Circular 2024-1 permits hired influencers to utilize tagging functions to link directly to the industry member’s account on the particular platform and thereby satisfy the mandatory information requirements. As long as the industry member’s tagged account includes the required disclosures, the influencer advertising the product is no longer required to include the same information within their own post.