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Tuesday, March 24, 2020

State Issues New COVID-19 Guidance to Local Liquor Control Commissions


Last week, in response to the COVID-19 global health crisis, Governor J.B. Pritzker issued an executive order requiring the closure of all bars and restaurants for on-premises consumption. To ease financial hardships imposed by the order and to promote social distancing, the Illinois Liquor Control Commission issued new guidance to local liquor commissioners across the state. The new guidance temporarily authorizes the delivery of alcoholic liquor subject to local approval, and defers to local liquor commissioners whether a municipality will allow “on-premises only retailers” to engage in off-premises sales.

Under these conditions, the Illinois Liquor Control Commission allows local liquor commissioners to permit temporary deliveries of alcoholic liquors. All retail licensees would be temporarily allowed to make curbside deliveries, home residential deliveries, and any other sale or delivery intended to promote social distancing. Local liquor control commissioners may also authorize retailers and temporary delivery licensees to use third party delivery services. However, all deliveries must be made in the original container and licensees may not sell or deliver pre-mixed cocktails normally intended for on-premises consumption. Deliveries made to a residence or to a curbside vehicle will require the delivery representative to observe the recipient at a safe social distance, and if necessary, require the examination of the recipient identification to ensure the recipient is over twenty-one. These temporary privileges are not generally allowed by law, and will be rescinded when the state terminates its COVID-19 emergency restrictions.

In additional guidance, the Illinois Liquor Control Commission announced it will accept the decision of a local liquor control commissioner to allow “on-premises only” retailers to sell alcoholic liquor off the licensed premises. License holders that normally have this privilege include combined (on/off consumption) retailers, off-premises only retailers, brew pubs, distilling pubs, brewers, and craft distillers. However, local authorities may now authorize an on-premises only retailer to make “package” or “to go” sales of alcoholic liquor for consumption off the licensed premises.

The Illinois Liquor Control Commission has also announced that renewal deadlines for state liquor licenses expiring March 31, April 30, and May 31 have been extended to July 31, 2020. As a result, state licenses will remain in effect even if the expiration date on its face indicates that it has expired.

Local liquor control commissioners can review the latest guidance on the Illinois Liquor Control Commission’s website, and consider authorizing these types of liquor sales that promote social distancing during the COVID-19 emergency.


By Daniel J. Bolin and Rain Montero

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