DEPARTMENT OF THE TREASURY
Alcohol and Tobacco Tax and Trade Bureau
TTB Ruling
Number: 2009–1
April 23, 2009
Taxable Weight of Tobacco Products
The Alcohol and Tobacco Tax and Trade Bureau (TTB) has received a
number of requests for advice regarding the taxable weight of certain tobacco
products. Specifically, we have been asked whether non-tobacco ingredients
that are included in roll-your-own tobacco, pipe tobacco, chewing tobacco,
and snuff products are included in the weight of the products for purposes of
computing the Federal excise tax. As an example, we have been asked
whether the tax on a consumer-ready cigar wrapper (also referred to as a
“blunt wrap”) is calculated based on the weight of the finished product or only
on the weight of the tobacco content of the finished product.
Background
The Federal excise taxes on tobacco products are imposed under
chapter 52 of the Internal Revenue Code of 1986 (IRC). Under 26 U.S.C.
5702, “tobacco products” are defined as cigars, cigarettes, smokeless
tobacco (that is, chewing tobacco and snuff), pipe tobacco, and roll-your-own
tobacco. Section 5702 also defines each of these specific tobacco products,
as follows:
The term “cigar” means “any roll of tobacco wrapped in leaf
tobacco or in any substance containing tobacco” other than any roll of
tobacco which is a cigarette within the meaning of cigarette set forth below.
(26 U.S.C. 5702(a))
The term “cigarette” means “(1) any roll of tobacco wrapped in
paper or in any substance not containing tobacco, and (2) any roll of tobacco
wrapped in any substance containing tobacco which, because of its
appearance, the type of tobacco used in the filler, or its packaging and
labeling, is likely to be offered to, or purchased by, consumers as a cigarette
described in paragraph (1).” (26 U.S.C. 5702(b))
The term “snuff” means “any finely cut, ground, or powdered
tobacco that is not intended to be smoked.” (26 U.S.C. 5702(m)(2))
The term “chewing tobacco” means “any leaf tobacco that is not
intended to be smoked.” (26 U.S.C. 5702(m)(3))
The term “pipe tobacco” means “any tobacco which, because of its
appearance, type, packaging, or labeling, is suitable for use and likely to be
offered to, or purchased by, consumers as tobacco to be smoked in a pipe.”
(26 U.S.C. 5702(n))
The term “roll-your-own tobacco” means “any tobacco, which,
because of its appearance, type, packaging, or labeling, is suitable for use
and likely to be offered to, or purchased by, consumers as tobacco for
making cigarettes or cigars, or for use as wrappers thereof.” (26 U.S.C.
5702(o), as amended by Pub. L. 111-3)
The same definitions appear in the TTB regulations in 27 CFR parts
40, 41, 44, and 45. In general, each of the products listed above is subject to
tax upon removal from the factory or, in the case of imported products,
release from customs custody. The applicable tax rate for each product
appears in section 5701 of the IRC (26 U.S.C. 5701). The taxes on cigars
and cigarettes depend upon the weight and quantity of the products when
they are removed from the factory or released from customs custody. Cigars
that weigh 3 pounds per 1,000 units or less are subject to a different tax rate
than cigars that weigh over 3 pounds per 1,000 units, and the same applies
to cigarettes. The taxes on snuff, chewing tobacco, pipe tobacco, and roll-
your-own tobacco are based upon the amount (by weight) of the product
removed from the factory or released from customs custody.
With regard to cigars and cigarettes, Rev. Ruling 64–11, 1964–1 C.B.
573, held that where cigars or cigarettes are manufactured with filters or
mouthpieces as an integral part of the finished product, the filters or
mouthpieces must be included in the weight of the cigars or cigarettes in
determining the weight of the product per thousand for tax purposes. The
same rationale applies to all tobacco products, that is, that the tax is imposed
under section 5701 on the finished product which encompasses all integral
ingredients and components, including non-tobacco ingredients and
components.
TTB Determination
Held, that for purposes of calculating the Federal excise tax, the
taxable weight of a tobacco product is the weight of the finished product,
including all integral tobacco and non-tobacco ingredients and components,
but excluding the immediate package or container in which it is removed or
imported.
Held further, that a consumer-ready cigar wrapper (or “blunt wrap”) is
subject to tax as roll-your-own tobacco, with the tax to be determined on the
basis of the weight of all ingredients and materials incorporated in the
finished product.
Date signed: April 23, 2009.
Signed by John Manfreda
John J. Manfreda
Administrator
Alcohol and Tobacco Tax and Trade Bureau