COVID-19 Update: FDA and TTB Response to Increased Demand for Alcohol-Based Hand Sanitizer Production

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As the novel coronavirus crisis continues to escalate, the demand for hygienic products such as hand sanitizer has dramatically increased. In response, many businesses, such as food and industrial and beverage alcohol manufacturers, are seeking to produce alcohol-based hand sanitizers using certain food grade materials, or to produce alcohol to be used in production of such sanitizers. In recent days, federal agencies such as the Food and Drug Administration (FDA) and the Alcohol and Tobacco Tax and Trade Bureau (TTB) have relaxed certain regulatory requirements for the production of alcohol-based hand sanitizers, in part, to respond to the call for food grade materials in such hand sanitizer products. This post provides a brief overview of the recently issued guidance, reflecting updates made to the FDA policies as of March 27 and to the TTB policies as of March 26.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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