If you read anything…
TTB
June 2023 - March 2024
The Alcohol and Tobacco Tax and Trade Bureau (TTB) is a bureau under the U.S. Department of the Treasury that regulates and collects taxes on alcohol, tobacco, firearms, and ammunition.
TTB has a long history of making decisions that impact their industry members without getting their input first. Overtime, this created a difficult to understand and convoluted experience for them to become and stay compliant with TTB. However, organizationally the bureau was beginning to see and understand the value of understanding industry member experiences and prioritizing their needs.
Our goal was to help TTB learn about their industry members and show them how to apply this knowledge when making decisions across the bureau every day. In order to achieve this goal, we left TTB with a variety of artifacts detailed below.
what we did
Personas
Journey Maps
Clickable prototype illustrating what a streamlined experience for their numerous products looks like
Why it mattered
TTB already wanted to embrace empathetic thinking and human-centered design but had trouble seeing it in action. From the beginning of our time on this project, it was clear that design decisions were happening every day and across the organization. The majority of the time by people without a design background. TTB did not, and still does not, have a formal research or design “shop“. Therefore it was important for work to be something that could be woven into the organization's fabric and not just something that would sit on a shelf in someone’s office.
My roles
UX Researcher
UX Designer
UI Designer
tools
Zoom
Miro
Figma
US Web Design System
Phase 1: Understanding TTB
Discovery
“Explain it to me like I’m an alien”
Whenever I start working with a new client, I’ve started adopting this approach. Of course, I’ve done my homework before kicking off any new project, but I think the insight you get when someone walks you through their day-to-day in this way highlights certain aspects of their experience that would’ve been missed otherwise. People often begin to normalize the negative aspects of their routines, and chock it up to it just being the way things are. However, I’ve found a lot of success in challenging this mindset using this approach. With the several and very complex processes and requirements associated with TTB, this approach was almost necessary. As a team, we applied this mindset to almost everything from stakeholder meetings to interviews we conducted with industry members.
Painting the picture
After numerous stakeholder interviews, and then interviews with actual industry members, we could finally paint a picture of the vastness and diversity of TTB’s section of the American people they are trying to serve. For a long time at TTB, there was an unspoken attitude towards their industry members that they all have the same needs and challenges. This could not be further from the truth. Out of all the projects I’ve done as a UX designer, I can confidently say that this user group was the most diverse and complex user group I’ve encountered to date.
Visualizing TTB
TTB has two main functions: regulation and tax collection. However, depending on the industry you belong to you may only need to pay taxes to TTB. Other industries have to abide by TTB regulations and pay taxes. This information is not made clear on TTB’s website, so below is a visual hoping to explain the TTB landscape in simpler terms. As seen in the visual, even within the same industry some sub-industries have to abide by specific TTB guidelines. For example, distilled spirits must abide by rules that don’t apply to wine or beer. Then certain industry members that fall into the non beverage alcohol, have to follow their own set of rules and not pay taxes while others within the larger alcohol industry do. It’s all very confusing, and the burden to understand all of these intricacies of TTB is on the industry member who is just trying to run their business and do the right thing.
TTB Requirements
At a high level, these are the main requirements for industry members at TTB. The order, frequency, and quantity of each requirement vary widely depending on factors such as the industry, product type, and business size, to name a few. It’s up to industry members to navigate these many requirements and understand the capacity in which they apply to them. There’s no clear guide to walk industry members through what they need to do or how. This creates a lot of confusion and anxiety for industry members who just want to run their business and follow the rules. According to those we talked to, most requirements with TTB share this point. You often don’t know you’re doing anything wrong until you get a scary message from TTB.
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Industry members usually need at least one permit in order to conduct business legally. The permitting process is possibly the most complex and difficult to understand out of all the TTB requirements. This is because depending on a multitude of factors like your industry, product, or business type your permit requirements could be totally different. A business's permit requirements are so specific to their unique situation that there really is no one size fits all guidance. However, all the burden for figuring what permits are needed falls on the shoulders of industry members.
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The purpose of submitting a formula to TTB is so that the agency can verify that you're meeting the requirements it has set for a given product type. Not all industry members need to submit a formula, and it can be tricky to know if you need to or not. One example of a product that would need a formula is any type of distilled spirit. TTB needs to ensure that the ABV and core ingredients are in line with their requirements for a given spirit. To further complicate matters, sometimes you'll need to send a sample of the product to a TTB lab so that it could be referenced with the formula you submitted. It's very difficult to figure out whether any of this even applies to you.
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A lot of work goes into getting the label we see on shelves approved by TTB. TTB is typically checking that all required information is on the label and that the language used is not incorrect or misleading in any way for consumers.
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While taxes is the touchpoint most industry members have in common when it comes to how they interact with TTB, there's still a great deal of variation in how much you need to pay in taxes and how often. It's often not until years later that you find out you've actually been paying the wrong amount and are facing numerous hefty fees.
A siloed Digital Landscape
For every TTB requirement, there is a digital product. While industry members appreciated TTB moving toward digitizing their processes, they did not appreciate needing to navigate to 5+ portals, each requiring their own unique login credentials. This created a siloed digital experience that over time would contribute to the overall administrative burden they’re already experiencing. TTB had already realized the need to create a more seamless digital experience for their industry members, but they were moving in the direction of putting their out-of-date legacy systems behind a newer interface. We were trying to show TTB why just adding a fresh coat of paint would not be enough to improve the experience of industry members.
Above is the original TTB.gov homepage and an improved version that TTB was trying to implement. While the improved interface on the right is cleaner and easier to navigate, it still does not address the severe usability issues of the tools still lurking behind the new interface. Once users click one of the buttons to access a tool, they’re still presented with a very dated interface that is difficult to use. This effort at TTB was to create a better “one-stop shop” for completing your TTB tasks, however, migrating to a new CMS and following a new design system was not enough to solve the very real issues behind this nicer-looking facade. Some of the big takeaways we learned about the digital tools that helped inform the clickable prototype are below.
Phase 2: Understanding Industry members
Big Takeaways
Unclear Applicability
Industry members are often tasked with understanding which parts of TTB regulations apply to them and in what capacity. However, clear and easy-to-follow guidance from the TTB is lacking. As a result, many industry members turn to blogs or seek advice from more experienced peers. Those who can afford it hire consultants to navigate the complexities of TTB regulations. While these alternative methods help bridge the guidance gap, they disadvantage business owners who are unaware of these resources or cannot afford them, hindering their ability to effectively run their businesses.
After conducting remote interviews with 22 industry members, these were the universal challenges they were dealing with. We recruited participants with the help of a volunteer pool that TTB had set up before our work with them. Due to the nature of how the volunteer pool was set up, the majority of participants fell into the alcohol commodity at TTB and we were only able to talk to a couple of tobacco and firearms. However, we did learn a lot about how complex the alcohol commodity actually is. Beyond the variety of alcohol products, all these other factors affect how difficult navigating TTB will be for someone (more on that below).
Convoluted language
Most of the content on TTB’s website is pulled directly from the regulation. It is not easy to understand; therefore, submissions to TTB are often submitted incorrectly and need substantial corrections. This is frustrating for industry members and TTB alike. If instructions were presented in a way that were easier to understand, it would alleviate challenges felt by industry members and reduce the load on TTB touchpoints like the call center and helpdesk.
lack of Transparency
When someone submits something for TTB approval, it is like sending it into a void. There’s no estimate for the expected turnaround, and industry members are left in the dark and unable to conduct business indefinitely. They often don’t hear back from TTB for sometimes months and they learn their submission has been rejected. They then need to start the process over.
user personas
After conducting interviews with industry members, we created the following four personas. Each persona experiences the pain points detailed above but the severity to which they're affected by them exists on a spectrum. Different factors like someone’s knowledge of the law, time available in their day, or tolerance for administrative burden can affect how much of an obstacle these pain points will be in a business becoming TTB compliant. Something that would be considered a major annoyance to one persona could be an insurmountable challenge for another.
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Most likely a small business owner with fewer brands/products that is juggling regulatory tasks on top of everything else. They are responsible for staying compliant, they take it seriously, but they are less confident and have less experience. They tend to work on TTB matters on the weekends or late at night; may have long dormant periods of interaction with TTB.
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The business has a small team or one person (often part owner, often the spouse) who focuses on the logistics for the business, including, but not limited to compliance and regulation. They are more tenured and have put in a lot of time and effort creating personalized processes to streamline their regulatory and logistical tasks.
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Medium to large sized business with the resources to hire a dedicated team that focuses on logistics, compliance, and sometimes HR. These teams often have a small number of people focused on TTB specifically and access to cross functional teams (i.e. marketing, research + development, accounts payable, etc.).
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The Third Party Professionals are consultants who help businesses of all sizes complete regulatory tasks and stay compliant with both federal and state agencies. These consultants can be individuals or teams. They're well versed in all things TTB, and when they need assistance from TTB it's for a complex problem that requires specialized assistance and escalation.
Administrative burden is defined as the challenges and difficulties individuals encounter when interacting with bureaucratic systems. There are several types of burdens, often called “costs“. The administrative burden is present in almost everything we do, but it runs rampant in the government. Common examples of burden include filling out forms, compiling documentation, and trying to understand complicated regulations. Another very interesting aspect of burden is that its effects can be compounded and therefore felt even more profoundly. Sure one confusing form is burdensome, but now consider how the amount of burden increases when you now have to print out the form, scan it, and then upload it to a cumbersome website. This idea of how burden gets compounded over time was particularly relevant in the case of TTB. For example, industry members had to use a different portal for each of their TTB requirements. Each of them was difficult to use on their own, but the burden they created individually was compounded when considering that they each had their unique usability problems, their own login credentials, etc.
While no one wants to deal with administrative burden, some people have a greater tolerance for it than others. For industry members who would be categorized as Third Party Pros, understanding the nuances and navigating the complicated landscape of TTB is their full-time job. They work with their clients to make sure all requirements are met and their client’s business is compliant with TTB. However, on the other end of the spectrum, someone like a Multitasking Average Joe is the only employee of their small business trying to get off the ground. They’re busy developing their business, often as a team of one. They don’t have the same time in the day to dedicate or motivation to navigate TTB as someone who has extensive TTB experience that they use to help their clients. TTB is burdensome for everyone, but it affects those who identify with the Multitasking Average Joe the most.
(To read more about administrative burden, check out this book that I think every UXer should read: Administrative Burden: Policymaking by Other Means)
Someone’s legal literacy refers to how well they can understand the language of legal documents. A common term for this kind of language is “legalese“. Similar to someone’s tolerance for administrative burden, the Mulitasking Average Joe is on the opposite end of the spectrum compared to the Third Party Pro. Through our interviews, we learned that the vast majority of those who go into TTB consulting has backgrounds as paralegals or were former TTB employees. In contrast, someone like a Multitasking Average Joe has close to no legal background or any familiarity with complex legal language.
As mentioned earlier, the time available in someone’s day to dedicate to TTB related matters can affect their tolerance for administrative burden. This visual is not meant to say that someone like a Third Party Pro has all the time in the world. They’re busy too. They often have several clients, each with their own unique situations with regard to TTB. This visual is meant to convey TTB can be what someone spends the entirety of their days doing or it could be something they have to try and squeeze in because they’re juggling many other responsibilities for their business like product creation, pay roll, etc.
Focus on Multitasking Average Joe
After reviewing our personas in relation to the 3 factors that would make their TTB experience easier or more difficult, we realized that Multitasking Average Joes and Third Party Pros exist on opposite ends of the spectrum. We also saw that Multitasking Average Joes typically have the least amount of resources and carry the most TTB related burden. Because of this, we wanted whatever we designed to focus on helping Multitasking Average Joes first (going to call them MTAJs going forward). By designing for MTAJ who needs the most help first we could build the foundation for a solid experience everyone would benefit from. Once that foundation was built, we could begin incorporating efficiencies and tailoring the experience to the needs of the other personas on the other end of the spectrum and everywhere in between.
Not another report
For the majority of my past projects with the government, the big deliverable at the end is usually a report detailing our research findings and recommendations. These reports definitely serve a purpose, but there’s always the fear that they’re just going to gather dust on someone’s desk. We wanted this project to be different. While we did give TTB a big report with everything we learned, our recommendations, and a “how to” of our process, we also provided them with a comprehensive clickable prototype that illustrated what designing for the insights from our research looked like.
The prototype is meant to show what a streamlined and user-centric experience looks like. We made it clear to TTB that our prototype is not meant to be prescriptive by any means, but more so a representative of possible solutions that can go on to be tested and iterated upon after we left. It’s meant to show them the value of prototyping and testing before developing and how making space for iterative designing leads to the best outcomes.
designing for USer needs, not TTB constraints
When talking about TTB constraints I don’t mean technical constraints around different software or a particular CMS. The constraints I’m referencing have to do with the fact that at the end of the day, TTB is a regulatory body. A large portion of its employees are lawyers or have some kind of legal background. So there was usually an emphasis on including legal language “as is“ and an expectation that industry members should know how to understand it. Examples of this could be seen in content on TTB webpages to even micro-copy on buttons. At the time we started working with TTB, there had already been some efforts to incorporate more plain language and intuitive processes, but they struggled to see it in action. A goal of the prototype we were creating was to show them that designing for user needs while simultaneously meeting legal requirements could be done.
Something that kept coming to mind when trying to figure out how to design for both user needs and legal requirements was that famous Julie Andrews line in Mary Poppins, “A Spoonful of sugar helps the medicine go down“. If we have to keep all these legal requirements in mind when designing for users with no legal background, how might I incorporate the metaphorical spoonful of sugar into redesigning TTB’s digital tools? If the processes themselves can’t change, how might my designs help make TTB more manageable for industry members?
I’d seen this approach taken with other private sector products, and a perfect example is Turbotax. They somehow managed to make doing my taxes easier, and dare I say kind of enjoyable? I knew similar principles could be applied to TTB, now it was a matter of getting TTB onboard.
User stories
Unclear Applicability
“As an industry member, I want to know what parts of TTB apply to me so that I can efficiently become and stay TTB compliant without needing to spend time and money searching for guidance elsewhere.“
To guide the design of the prototype and make sure what I designed was rooted in what I heard during interviews with industry members the user stories we made were directly tied to the 3 big points mentioned earlier. While these are not all the user stories created, they were the key ones.
Convoluted Language
“As an industry member, I want clear, step-by-step instructions on how to correctly comply with specific TTB regulations, so that I can avoid trial and error and ensure compliance from the start.”
lack of Transparency
“As an industry member, I want to receive regular updates and estimated turnaround times for my TTB submissions, so that I can manage my expectations and make informed business decisions.”
Prototype highlights
The prototype had two goals: illustrating our research findings and giving TTB a solid first iteration of a prototype to test after we left. Here are some concepts for improvement that the prototype highlighted.
improved visual heirarchies
A design challenge consistent across TTB’s digital products was that they were overly crowded, leaving users overwhelmed and unable to find what they needed. Users provided feedback that they often didn’t know where to look first and that their eyes would begin to glaze over the screen. During our early interviews with industry members, we discovered that much of the information they wanted from TTB’s website was actually already there, but it was just difficult to find. This was due to poor site navigation and how easy it was to overlook information, even while on the correct page, because of how much content was on each page without any consistent or thoughtful organization. Many site pages had competing visual elements and lacked a clear focal point. In redesigning these pages, we considered who was most likely to visit each page, anticipated their needs and questions, and designed the page’s visual hierarchy with that in mind.
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After
Relevant information when and where you need it
As mentioned when discussing visual hierarchy, much of the content users expressed wanting to see already existed. It was just very difficult to find, or in this case not available in the when and where they needed it. A theme in our research was that industry members wanted TTB to be more transparent about how long application processing times would be so that they could make important business decisions and manage their expectations. When we shared this with TTB, they were confused and directed us to the site page on the left. TTB thought that they were meeting industry members’ needs by providing this information on estimated processing times, but our research demonstrated that while this information did exist it did not live in a place where it was going to be the most useful to industry members.
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After
Emphasis on plain language
The image on the left shows the regulations as presented by TTB, while the image on the right displays a prototype screen that interprets and presents this regulatory content in a way that remains factually correct, unambiguous, and, most importantly, easy to understand. One recurring theme in our research was that industry members often expressed confusion about what they needed to do and how to do it. Although the necessary information was technically "in the regulation” according to TTB, this perspective fails to consider that most industry members lack the legal literacy to comprehend complex regulations or the time needed to decipher them. This prototype screen demonstrates how using plain language can significantly improve understanding therefore creating a better experience.
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Roadmap Generator
It’s typically much easier to approach a complex or daunting task after it’s been broken up into smaller and more manageable steps. That’s the concept I leaned on here. In order to figure out which parts of TTB apply to you and in what capacity, industry members had to sift through very dense pages with lots of regulatory information in language was that was difficult to understand to figure out which parts to even apply to them. The concept of designing something that allowed industry members to provide information to TTB incrementally and the agency being able to tell them what needed to be done was something TTB identified as a need, and that was confirmed in our research. By answering questions about yourself and your business, you’d be able to generate a personalized guide of what TTB requirements you would need to meet.
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Baked in cues and blocks to keep users on the correct path
A challenging aspect of TTB compliance is that it involves multiple steps that must be followed in a specific order, yet this sequence is not clearly communicated to industry members. The reason ordering matters is partly because of the way regulations are written and also due to how TTB organizes information on the backend. While reworking TTB’s backend was beyond the scope of our project, we focused on improving the interface of TTB tools to guide users through the correct compliance workflow, minimizing confusion and wasted effort.
For example, on the original screen of the formulas workflow on the left, there was no indication that users needed an approved permit to begin their formula application. While users could proceed without this prerequisite, their applications were inevitably rejected due to the missing permit, leading to frustration and the need to repeat the process. To mitigate this, we introduced a design solution using disabled buttons to act as blockers, preventing users from progressing without fulfilling essential steps. Each blocker was accompanied by clear explanations, allowing users to correct their course and avoid unnecessary rework. This design improvement aimed to streamline the process, reduce user frustration, and save time.
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After
Hopes and receptions of the prototype
As a team we knew we did not want to give TTB a big report of research findings and part ways. We wanted to create an artifact that wouldn’t collect dust on someone’s shelf. Based on the reception we got after sharing the prototype with TTB, we feel confident that it will live on as a tool to drive conversations forward and be a callback to how our work showed why empathy and keeping industry members at the center of decisions matters. Here’s some of the positive feedback we got.
“I really appreciate what you're showing, even if it's not technically correct. It helps us envision what's possible “
“You figure out the flow first, is this flow possible, how simple can we make it, when it comes time to argue about the words then you can bring in the users and make sure they understand it and if they can't…well then 90% of our testers don’t know what this means and we need to come up with another word.”
“You’ve provided such a tremendous service to TTB. We’re all very excited about the future, building from the vision you’ve helped to crystallize.”