Connecticut Executive Orders and Regulatory Guidance

Executive Order 7D (March 16, 2020)

On premises retailers (bars and restaurants) shall only serve food or non-alcoholic beverages for off-premises consumption (takeout) through April 30, 2020 unless order is earlier modified, extended or terminated.

Suspension of Enforcement of Bottle Bill Redemption Requirements by DEEP (March 17, 2020)

The Department of Energy & Environmental Protection announces that it will suspend enforcement actions against retailers (grocery stores and package stores) that refuse to accept the return of empty beverage containers.

Guidance on Consignment Sales from Department of Consumer Protection (March 23, 2020) 

“Due to the dramatic effect that COVID-19 has had on the liquor industry, in particular our on-premises consumption locations, the department finds that ‘good cause’ exists that alcoholic liquor purchased by an on-premise consumption  premises between March 1, 2020 and March 17, 2020  may be returned to the wholesaler or manufacturer who the retailer purchased the alcohol from in return for credit, at the option of the wholesaler or manufacturer.” 

Executive Order 7G (March 19, 2020)

On premise retailers (bars and restaurants) and manufacturers (breweries, distilleries, farm wineries) are permitted to sell sealed alcoholic beverages with food for off-premises (takeout) consumption.  The Department of Consumer Protection Implementation Order concerning rules for specific types of permit holders, details concerning hours of sale and quantities to be sold is available here: Implementation Order.

Executive Order 7R (March 31, 2020)

Package stores and grocery stores are permitted to offer curbside pickup to customers in any space adjacent to their premises during the days and hours allowed for legal sales.

Executive Order 7S (April 1, 2020)

The statutory period of credit on sales between wholesalers and on-premises retailers (bars and restaurants) is extended from 30 days to 90 days for all credit sales open as of March 16, 2020.  Delinquent (posted) retailers as of March 16, 2020 are not entitled to this extension of credit.

Executive Order 7T (April 2, 2020)

On premise retailers (bars and restaurants) and manufacturers (breweries, distilleries, farm wineries) are permitted to deliver containers of sealed alcoholic beverages directly to customers.

The Department of Consumer Protection Implementation Order concerning rules for specific types of permit holders, details concerning hours of sale and quantities to be sold is available here:  Implementation Order.

Federal Tax and Trade Bureau (TTB) Orders and Guidance

Guidance Concerning Consignment Sales (March 13, 2020)

“Given the unexpected and widespread nature of the concerns involving COVID-19, TTB will not consider returns of alcohol beverage products purchased to sell during such cancelled events to violate Federal consignment sales rules provided the products were not initially purchased or sold with the privilege of return.”

Postponement of Excise Tax Return Filing and Payment Dates  (March 31, 2020) TTB Industry Circular 2020-2

To assist businesses being severely impacted by COVID-19, TTB has postponed excise tax filing and payment due dates on wine, beer and spirits for 90 days where the original due date falls on or after March 1, 2020, through July 1, 2020.

For additional information, please contact:

David S. Hardy
(203) 784-3119; [email protected]

James K. Robertson Jr.
(203) 575-2636; [email protected]