Building Personas to Humanize TTB’s Industry Members
June 2023 - December 2023
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.
Like most federal agencies, TTB had a 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 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. This case study focuses on the first phase of our time working with them which involved research with industry members and resulted in 4 personas. For a case study on the design work I did that was informed by these personas, see this case study.
Why it mattered
We chose to create personas for TTB’s industry members to challenge a common assumption across the agency: that all industry members (IMs) shared the same challenges and could be treated as a single, uniform group. We initially hypothesized that there would be at least some variation in experience based on commodity type (alcohol, tobacco, or firearms), but what we uncovered during our research revealed far more complexity than expected — even to us.
The resulting personas aimed to illuminate the true diversity within TTB’s user base and demonstrate just how many nuanced factors shape each industry member’s experience. Not only did this dispel internal assumptions, but it also served as a powerful tool to reframe how the agency thinks about serving its stakeholders.
My roles
Researcher
tools
Zoom
Miro
what I made
4 personas
Understanding TTB
Leading with curiosity
I approach every project with curiosity and a blank slate — a mindset that’s been especially valuable in government work. People often normalize frustrating processes, accepting them as “just the way things are.” By asking thoughtful questions and observing without assumptions, I aim to surface those hidden pain points and show teams that things can be different.
At TTB, where processes are particularly complex and regulated, this mindset helped us uncover meaningful insights — both in stakeholder meetings and during interviews with industry members. While I always come prepared, I’ve learned that listening to someone walk through their day-to-day often reveals what documentation and prep alone can’t. It’s a practice that consistently leads to more human-centered, actionable outcomes.
TTB by commodity
To begin understanding the many aspects of TTB, we started by mapping the industries and commodities it regulates and taxes. This map served as the foundation for our recruitment strategy. Fortunately, we had access to a database of industry members who had voluntarily opted in to provide feedback through TTB’s website. The database was organized by commodity, which reinforced our initial hypothesis: a person’s commodity type would be the primary factor shaping their experience with TTB.
The reasoning behind this thinking was that some industry members only interact with TTB to pay taxes, while others must also comply with detailed regulatory requirements. Even within the same industry, sub-categories face different obligations — distilled spirits, for instance, are subject to rules that don’t apply to wine or beer. We believed that an industry member’s commodity would strongly influence their overall experience, and we hoped this approach would help us identify which groups were facing the most friction.
(Spoiler: it didn’t — but more on that later.)
TTB by Requirements
Assuming that the specific requirements tied to a given commodity likely shaped someone’s overall experience with TTB, we aimed to gather feedback on these requirements directly from industry members during our sessions.
At a high level, these are the main obligations industry members must fulfill when working with TTB. However, the order, frequency, and complexity of these tasks vary significantly depending on factors like industry type, product category, and business size. It’s largely up to industry members to determine which rules apply to them and how to stay compliant.
There’s no centralized or step-by-step guide to help users understand what they need to do or when. We also hypothesized that this lack of guidance creates a baseline level of confusion—and sometimes anxiety—for people who are simply trying to run their business and follow the rules.
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Industry members usually need at least one permit in order to conduct business legally. The permitting process proved to be the most complex and difficult to understand out of all the TTB requirements based on our research. This is because depending on a multitude of factors like your industry, product, or business type your permit requirements could be totally different. The burden for figuring what permits are needed falls on the shoulders of industry members. Delays as a result of doing things “incorrectly“ were common, and these caused industry members time and money. For example, some IMs needed to have a physical location rented in order to even apply for a permit. It could easily be months of the space sitting empty for a permit to be approved and they can begin operating.
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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.
Clues to something bigger
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 gap, they disadvantage business owners who are unaware of these resources or cannot afford them, hindering their ability to effectively run their businesses.
As mentioned earlier, our initial hypothesis—that an industry member’s commodity type would be the main factor shaping their experience with TTB—only scratched the surface. While there was some truth to it, the reality was far more nuanced. The challenges people faced often transcended industry, commodity, or regulatory requirements, pointing to deeper, more universal patterns in their interactions with the agency.
After conducting remote interviews with 22 industry members, we began to see clear themes emerge. While some participants reported significant struggles with TTB and others experienced fewer issues, nearly all of them shared similar challenges—though to varying degrees. Notably, several participants reflected that many of these challenges felt more intense earlier in their engagement with TTB, and became more manageable over time as they gained experience.
This insight was our first clue that we may have been thinking about personas in the wrong way—and that a pivot was needed.
Convoluted language
Most of the content on TTB’s website is pulled directly from the regulation. It is not written in language that is 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 written in plain language and 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.
Hidden factors
The factors that truly shaped an industry member’s experience with TTB weren’t obvious at first. We entered these sessions knowing only what commodity each participant worked in — not their role, background, or level of experience. Much like TTB itself, we approached this research without many filters, and in hindsight, that worked to our advantage. Since this type of user research hadn’t been conducted before, going in with an open mind allowed us to treat it as true discovery — helping us understand a broad and complex group, while also informing how future, more targeted research efforts could be structured. One of our key outcomes was identifying a more effective way to recruit participants moving forward.
As we began synthesizing our findings, we noticed clear patterns connecting who a participant was with what they said and how they experienced the challenges. The same pain point could be a minor annoyance for one person but a major roadblock for another — often depending on their role, experience level, or familiarity with TTB processes.
In other words, personal context influenced how much friction someone felt — or how much administrative burden they were willing or able to tolerate. Before diving into why that varies, it’s important to understand what administrative burden is and why it matters.
Administrative Burden
Administrative burden is defined as the challenges and difficulties individuals encounter when interacting with bureaucratic systems. 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. There’s different types of burdens, also referred to as “costs“: Learning, Compliance, and Psychological costs.
Learning Costs
This relates to the time and effort it takes for someone to understand a process and their eligibility for that process.
For example: reading a website to understand guidance, asking questions like, “Can I do this? How do I do it?“
Compliance Costs
This relates to time, effort, and other resources needed to meet the requirements for a process.
For example: gathering documentation, printing a form, driving to a meeting.
Psychological Costs
This relates to the emotional stress or stigma related to the process.
For example: applying for unemployment insurance can be both stressful because it’s associated with a job loss, but it’s also an experience that has significant stigma in our society.
(To read more about administrative burden, check out this book that I think every UXer should read: Administrative Burden: Policymaking by Other Means)
The research we conducted showed that all 3 costs were present in every participant’s experience, but again the severity differed. The reason the severity and someone’s tolerance to each cost seemed to differ mainly had to do with their legal literacy and the time they had in their day for TTB tasks. Both of these factors were strongly driven by the type of role they played in their company and professional experience.
Legal literacy
A person’s legal literacy refers to how well they can understand the language used in legal documents — often called legalese. For many industry members, this poses a significant barrier. Much of the content on TTB’s website, particularly guidance on eligibility and compliance, is pulled directly from regulatory text rather than written in plain language.
This creates challenges for users without legal or regulatory backgrounds. Many spend considerable time — and in some cases, money — trying to interpret what is required of them. Some turn to consultants simply to understand how to stay compliant. This adds stress, delays, and additional burden to those who are just trying to follow the rules. The amount of burden this creates for someone with high legal literacy is significantly lower than the amount for an average person without legal literacy. Therefore someone with a legal background may be able to tolerate higher amounts of administrative burden driven by high learning and compliance costs as a result difficult to understand legal language.
Time in the day for TTB tasks
The amount of time industry members could dedicate to TTB-related tasks varied significantly across participants. For some, TTB was just one of many responsibilities they had to juggle while running their business and producing their product — often treated as an afterthought or administrative burden. For others, TTB compliance was their primary role, allowing them the time and focus to navigate its requirements more thoroughly. These were typically former paralegals who became TTB consultants or regulatory employees at companies who were taught how to navigate TTB.
In some cases, participants with dedicated time also had legal or regulatory backgrounds, which made interpreting requirements a bit easier — though this wasn’t always true. Regardless of business size or experience, TTB compliance demands time. The key difference was whether participants had that time to invest. Someone with dedicated time to invest towards TTB tasks may be able to tolerate higher amounts of administrative burden than someone with less time to “figure it out“.
Humanizing TTB
The Personas
Our goal with these personas was twofold: first, to help TTB better understand who their industry members are, and second, to demonstrate how this understanding could inform day-to-day decision-making across the bureau. We also aimed to challenge a common assumption within the agency — that all industry members face the same challenges and can be treated as a single, uniform group.
As researchers, we knew the industry member population was far more diverse, but through our work, we uncovered exactly how and why their experiences differ. We developed four personas, each rooted in — and differentiated by — key factors that influence an individual’s tolerance for administrative burden and the characteristics that drove their individual tolerance for administrative burden. Meet them below.
Multitasking Average Joe
They’re usually 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 with TTB.
Works on the weekends or late at night; may have long dormant periods of interaction with TTB and can forget how they figured something out the last time.
Not likely to have much legal literacy
Low tolerance for administrative burden
Motivated by selling their product to consumers
Dedicated small business pro
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.
Want to use the documentation and efficiencies they’ve built for themselves so that they can make dealing with TTB easier.
Want to document their process so that they can streamline all regulatory work later.
Slightly more tolerance for administrative burden as they have more time to dedicate to TTB, but they’re still juggling other business logistics like payroll, distribution, etc.
Motivated to see their business succeed as there’s usually a personal connection or investment.
Inside Pro Team member
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.).
Usually onboarded by their company on what to expect with TTB or they have previous experience with TTB.
Oftentimes inherited support materials and checklists from their predecessor on how to become and stay TTB compliant.
High tolerance for administrative burden because of the time they’re able to dedicate to TTB. Usually it’s their entire job.
Motivated by performing well in their current role at their company.
Third Party Pro
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.
Oftentimes have a legal background and were paralegals in the past.
Know the ins and outs of TTB very well as a result of how many times they’ve helped their clients through the process. Sometimes even know the specifics of TTB better than those working in the call center.
High tolerance for administrative burden given their typical legal background and time they can spend on TTB tasks, it is their full time job.
Motivated by providing their clients an easier TTB experience than if they were to do the process themselves. They want the client to have a smooth journey to becoming compliant and keep them in the know at all times.
Personas on a spectrum
As explained above these personas all experienced similar challenges, but the degree to which they experienced them varied as a result of a few factors. Here’s a visual showing where everyone sits with respect to administrative burden tolerance, legal literacy, and time in their day.
Personas in action
Informing a prototype
While the overarching goal of the personas was to help TTB recognize the diversity of their industry members and surface the real drivers behind their experiences, the personas also played a key role in shaping the next phase of our work: informing a prototype that reimagined TTB’s digital experience.
We already knew the existing systems were outdated and fragmented. But creating a better experience required more than just a visual refresh — it meant designing a system that could meet the needs of multiple distinct user types. By grounding our design decisions in the specific feedback we gathered from industry members and the insights captured in our personas, we were able to create a prototype that envisioned a more cohesive, user-centered digital experience.
Last I checked in, the prototype is still being used to guide product strategy and design across the agency — a testament to how well it captured both user needs and organizational potential
Learn more: Streamlining a Siloed Digital Experience at TTB.