gordon

I agree with Thatch. Ours is in an office/warehouse building with multiple tenants.

01/01/2018

So, I spoke with a recycler this morning and was told that (here in California) we need to register with the California Environmental Protection Agency and get a Toxic Substances Control’s identification number. Has anyone done this, or looked into it? Are there any concerns with doing this? I don't want to open a can of worms if that's where this could lead, especially if one of the above alternatives makes more sense. Thanks!

Is it legal to do a TIB on bottled products? Distillery A receives a barrel, via a TIB, from Distillery B and bottles the contents of the barrel. Distillery A now wants to send bottled products back to Distiller B. Who is responsible for paying the tax? Can "A" TIB it back to "B?" Thanks.

Does anyone know where I might get colored liquid that we could fill display bottles with for use in venues that are not licensed to sell liquor? (Is this legal?) I've tried food coloring water but after a few months, it either changes color or becomes cloudy. Thanks, Gordon

jrfalcon, I assume you are referring to the reports? If so, please check out this thread: Good luck!

Does that 3/10 of 1% apply to everything you make or just the products that are certified organic? Thanks.

Not sure if this is the correct place to post this, but will give it a shot. Does anyone know what the rules are with regards to producing brandy for wineries in California? What can we (distilleries) legally do for them and what can a winery legally do with the brandy that is produced? Assuming the winery does not have a distilling licence, but has the license required to do TIBs with a distillery: • Can a winery age brandy on their premises? • Can a winery bottle the brandy themselves? • If not, can the producing distillery bottle for them? • What would label requirements be? • Can a winery sell brandy made from their wine? • Can a winery provide tasting samples of their brandy? (I don't believe they can.) • Can the producing distillery sell (and taste) the winery's brandy (if agreeable with winery)? Thanks, Gordon

Did you get this up and running???

We do this with a local brewery also. No TIB required. However, we do record raw materials used (by the brewery) to make each batch and that is what gets reported, in pounds, not gallons.

Craig B. Rashkis Attorney at Law FARWELL RASHKIS, LLP 18 Park Avenue Los Gatos, CA 95030 Tel: (408) 399-0505 Fax: (408) 399-4321 www.farwellrashkis.com

I'm actually working on the Permits-Online screens and adding an amendment to register the various names we are using and/or are being used by those we are providing products for. However, I really am more concerned that we are doing things correctly with whatever we end up putting on the labels, when we get to that point, with regards to the 3rd-parties we are doing things with (e.g. - Good Food Spirits & Blue Bell Spirits) Thanks!!

dhdunbar, Thanks for posting the above info. I'm still a bit confused on what you have stated and hope you can help to clarify my [mis]understanding. Using the example you have above, let's say you are bottling a gin for Good Food Restaurant called "GFR Gin." I assume you don't need a trade name for "GFR Gin." (Or would you?) On the back of this label, you have indicated that it would state "Bottled by Good Food Spirits." I assume this means that no where on this label does it say anything about Right Way Distilling or ABC, LLC, correct? Taking this one step further, if ABC, LLC, dba Right Way Distilling was also distilling a vodka for another restaurant, "Blue Bell Restaurant" and called it "BBR Vodka" and on the back of the label it stated "Distilled by Blue Bell Spirits," then ABC, LLC would have to have filed for the trade name "Blue Bell Spirits" in order to meet TTB requirements. Does that also mean that ABC, LLC would need to also have a DBA filed for "Blue Bell Spirits?" (And one filed for " Good Food Spirits?") Lastly, would the above restaurants need to be registered as any kind of a manufacturer/producer/bottler with TTB? Thanks!!!

dhdunbar, did you ever get any feedback from TTB on this? Thanks, Gordon

Has anyone had to deal with this in California? We are being told by our local fire marshal that this would apply if the CA Fire Code points to this NFPA section as reference. If it does not, then it was not adopted by CA as approved. UPDATE = Chapter 57 of the Calif. Fire Code states the same statement about wooden barrels or casks.