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Hey everyone, Has anyone ever tried to get a formula approved with the herb Meadowsweet (latin name Filipendula ulmaria)? I'm experiencing a lot of difficulty with my TTB officer at the moment. I know of multiple products that list meadowsweet right on the bottle/label, so I'm curious if anyone has any ideas why they want to deny me use of this herb. I've gone through three rounds of formula corrections all coming back negative. What do you guys think?

I've been looking for a physical copy of 27 CFR Part 30, the TTBs gauging manual. I mostly want one for the tables and ease of use instead of printing tables out and putting them together in a big, clunky binder. Anybody know if these are available anywhere, or if they even exist?

Under 27 CFD 19.166, the code states "A statement of certification of accurate calibration shall be included in the description of tanks that are to be used for gauging distilled spirits or wine for any purpose." Could someone translate this from LAWYER into ENGINEER for me? Does this mean that if a tank is used for measuring volume, that it must be calibrated and certified?

in CFR 19.490 is the "series" product specific for case and/or bottle numbers? If a company has 2 products, A and B, would the first 10 cases/bottles of each follow as product A: 1-10 product B: 11-20 or are both A and B: 1-10 case/bottles? Thanks

I apologize in advance if this is a question I should have figured out the answer to by now. It's also probably a question best asked of a TTB agent, but I thought I would toss it here to see if anyone knew. I'm still in the planning stages, working on a distillery that would produce rum. Dunder is going to be a key ingredient to the flavor I'm looking for, but all of my research is telling me that it will take a while to get a good dunder pit going. I'm considering ways to get that in process while buildout, still delivery, etc. is happening. The key would seem to be that you want the dunder to have no alcohol left in it, lest you impede the growth of all of the fun bacteria. So... 1) Mix up a batch of molasses water, add yeast, boil the alcohol out, and let the bacteria take over. Can I do that without a DSP, if I don't intend to sell the alcohol? Alcohol is a byproduct of plenty of production processes, just not in that volume. 2) Mix up the molasses, leave it uncovered for a few days, maybe outside. Boil it to sterilize it again, then let the bacteria take over. Anyone have any experience with this?

If you buy spirits in bulk, and then bottle them in your facility, what equipment is required to get a DSP license? Obviously you don't need a still to finish the product, but would you have to get one anyways in order to comply with the TTB?

Is the 27 CFR the only place listing rules from the TTB? or is there another guide?

We need an Attorney or advisor to get a field agent to do his job. A new distributor in LA has been held up for 60 days due to a simple address change on a previously approved permit. We have product pre-sold and product waiting to ship. The TTB office states "No one can work on the other than the assigned agent." The agent has not responded to emails or phone calls.....My CA friends need help.

Dear Forum Members and Anonymous Info Gatherers, I am so very excited to announce that I will be in attendance at this years convention in San Diego and I look forward to seeing all my old friends and meeting so many of you that I have either communicated with already, or have yet to meet. I will be on the Expo floor located at booth #531 and I encourage all of you that are attending to stop by and introduce yourselves!!!! This year is going to be GREAT!!!!! Since I am always striving to be on the cutting edge of all things insurance and TTB bonding (if you have not read my whitepaper posted in the forums, go, read it right now! Actually, you can wait until you finish reading all of this post first, but then go immediately and read it!) I am super excited to announce that not only will I be in attendance this year, but as well I will have the incomparable Richelle Smith with me as well. Richelle is my TTB Bond underwriter and not only will she be there to assist in answering questions, SHE WILL ALSO BE ABLE TO UNDERWRITE AND ISSUE BONDS ON THE SPOT should you have a need. We will have all of the applications on hand as well as the ability to run all of the needed information and issue bonds right then and there. So, no matter if you are a "first timer" needing a bond for your up and coming distillery, or if you are just in need of a larger bond that you cannot procure though your "normal" channels, we have you covered. Oh, and BTW, our rates are the cheapest in the country for the last year and a half running. So you totally need to swing by and check that out as well since we do more of these than anyone else out there and we are fast, fun, friendly, and did I mention "cheap"!!!!!!!!! Last thing for your consideration, I will also be giving a presentation at the breakout session on Tuesday April 5th at 10:30 entitled, "Insurance: What you know, don't know, need to know" and I would love to pack the room! I promise it will be fun and not "boring old insurance", trust me, I get that insurance can be boring and a horrible topic. Not with me though, I hit all the fine points, the good stuff that you need to know and I keep it light unless you want very specified details. I can do that as well, but I like to keep that for only those that really want to know more as we get into the "nitty gritty" later on. Anyway, please, everyone stop by the booth, say "hi", get a bond while you are in the neighborhood (I want to keep Richelle super busy), and come listen to and interact with me during my presentation. I simply cannot wait to see everyone and I look forward to meeting many of you for the first time.

Hey all, I had a question about applying to formulas online. We have a re-distilled gin formula that has been approved for FONL and we think we have a very good gin. However, since we are being held up by some local issues and have the time we were thinking of doing some experimentation to see if we could make it even better. My question is can we submit an alternative recipe through FONL for the same product. For example if we have something called "The Best Damn Gin" approved as the brand name can we submit another formula for "The Best Damn Gin 2.0" and amend our COLA to correlate to it if we are approved. For clarification, we are not in production yet so we aren't trying to change the flavor of a product already on the market.

Is it possible to make a change to an approved ttb formula? For example: adding a small amount of sodium hydroxide to balance the pH of an existing product, or changing the bottling proof? I know the formulas allow some leeway in terms of how much of each ingredient is put in, but what if I would like to change something more than that? do I have to submit a totally new formula?

Hi All, I am looking for a good software company or a cloud based tracking system to insure we are paying the proper amounts of tax and the forms are filled out properly. Please give me any info or feedback that you have.

After much ado, we're in the process of getting our business going. LLC established, EIN, local zoning, building lease, still on order, bonding squared away... but now as I'm getting ready to start the big stuff - TTB paperwork, I'm not sure what order everything needs to be filed. It seems like a lot of the overviews completely gloss over building permitting and state liquor board registrations, and go straight to talking about Federal. In my mind it makes sense to go building permit, state application (I'm in Pennyslvania), and then TTB. But it doesn't look like TTB is looking for building permit documentation and if I can just send in a building diagram of our proposed layout, is that enough to get the federal work going while I get it submitted to the State? Or does the state need the Federal permitting information? I know there can be some overlap on things, but I can't seem to find any examples of how far you can push it. I don't want to trip myself up getting out of sequence. Anyone have some light to shed? Thanks!

Dear ADI Forum, I wanted to take a few moments to send out a heart-felt "THANK YOU" to the many of you that have made my exclusive distillery insurance program so successful to date! I just entered into my 45th state of distillery business and could not be any more pleased with the success that we have had and it is all thanks to you fine folks in the forums. You have been wonderful to work with, you have supported me from the beginning and have shared my information with others outside of the forums as well. I have had the great pleasure of getting to know many of you, watch you get going or grow over the last few years. As many of you already know, I have worked with distillery clients for many, many years, but not until I became involved with ADI and the forum was I able to connect with so many great people. I cannot think of any other way to put it besides just saying, "Thank You all so much, you mean the world to me."

Good morning! We have an opportunity to move our tasting room from a rather industrial, off-the-beaten-path location, to a high-traffic area in a very cool Main Street building. My question is, what kind of hoops do you need to jump through to make this happen at the Federal level. I don't think we'll have any problem with the state or the city. The rent is $250/month and we can be in there before Christmas. We have t-shirts, books and, of course, our vodka (soon gin and whiskey) to sell. Thank you. Cheers/ Brian

I've been having some real trouble understanding which hydrometers are necessary for operations. Does anyone know of a guide for the hydrometers needed for operation? I know we need to have NIST-certified equipment for proofing and gauging, but don't understand the ranges of SG for which we need. Can anyone share a list of ranges, use, quantity and whether NIST certified of your hydrometers? We're ready to spend on these, but want to make sure we're spending correctly. I've seen a few posts on this, but there seems to be some variance on how many hydrometers most folks purchase and the number that are NIST certified vs. those that are not. Thanks for your input. Any recommendations on where to buy (aside from Cole Parmer) are appreciated as well.

Good Day Everyone, As many of you may know, I was out of the office the last several weeks traveling around with the fam and just taking a bit of much needed R&R. Timing is everything though, and in this case I missed the timing. So, for those of you in the know, maybe you have already been hip to the recently released podcast that came out on 7/22/15 on the Firewater Network featuring yours truly. If not, that is why I am posting this here and now. If you would like to tune in at your leisure and listen when you like, I have included the link below of my interview with Zachary Farley of Firewater Network where we cover pretty much everything you want to or need to know about your distillery and the insurance and bonding aspect. I hope you give it a click and give it a listen. It is informative and gives you a pretty good understanding in regards to what you will need or possible what you may need to change about your current insurance program. http://firewaternetwork.us9.list-manage1.com/track/click?u=72f3e834e2ba795522e617a94&id=5105256efe&e=8d0f2409c3

Curious here, what is the proper way to evacuate a still - post distillation? To my understanding, we are supposed to capture all distillate, but some stills requiring the manway or a pressure release to be drained releasing what could be potentially hazardous vapors right? I don't think I've heard anyone talk about this and haven't came across it anywhere. Also, are people actually checking and recording each batch to verify that their waste distillates are actually below 10%?

Hello All, About to submit our DSP and had a quick question about Subpart D that hopefully someone can shed some light on. Is merchandise sales and tasting included in the DSP, or do you need to clarify those as "other business conducted on DSP premises". It is outside our bonded area, but located in the same building. Any advice?

Seeking a lease in an historic location in Kansas City. All the buildings in the area a big 4-5 story brick buildings so the owners would like to lease to multiple vendors (zoning is all industrial). Potential site owner is hesitant about leasing to manufacture & retail distillery and not being able to use the other floors for say leasing to restaurant that has a liquor license. My question is basically - if I own a building and lease to a distillery, could I also lease to a restaurant w/ a liquor license(on a different floor)? If I have no controlling interest in the distillery (ie. I just lease, no ownership) would the TTB restrictions prevent any other retail licenses for that location. http://www.ttb.gov/pdf/ttbp51008_laws_regs_act052007.pdf Any help or suggestions are much appreciated. Thanks, Alex

Insurance: a three tiered step-by-step guide for your distillery I am asked constantly by folks from all parts of the globe (literally) as to how the insurance process should go, what they need, and at what point do they need it. Actually, I am asked about this so often that I decided to sit down for a few minutes and put it into post since there must be more folks out there wondering the same thing. For the purpose of this post I am going to only address the process for the US at this point and do so at a 30,000’ perspective as to not bog anyone down in the minutia of deeper subject matter. However, if you are in “some other place” or would like a deeper understanding of some piece of insurance please feel free to message me or email me as I do have quite an extensive knowledge of the process in several other lands and a deep understanding of the nitty-gritty nuances of all of the insurance aspects. Anyway, on to the process. The typical insurance process, step one: You are applying for your DSP and you run into the section where it is calling for the DSB (Distilled Spirits Bond) that you need to give to the TTB in order for them to process your permitting. This aspect of the “insurance” side of things is perceived as one of the scariest and most difficult processes to struggle through. I am here to tell you that simply is not the case. Many people have horror stories or have heard from someone that this was the worst part of the whole process. That the bonding screwed up everything and set them back months, or that when they were finally able to get through this horrible process the bond ended up costing them an insane amount of money. Although many of those stories are true and oftentimes people do lose precious time or they indeed pay an incredible amount of money for their bond, it all boils down to one thing; the person they are working with. Knowledge and relationships are king when it comes to bonding and anyone that has worked with these types of bonds for years on end should be able to assist you through the process in the matter of a few minutes. From assisting in the figuring of the taxable liability amounts, to the application process, this truly should not take longer than about 15-30 minutes start to finish. Once those “meat and potatoes” aspects are figured out and the applications are complete you should be able to have the executed bond form in your hands and ready for submittal within 24-48 hours. If you are working with someone who has the knowledge and relationships in this industry, the bond should be a done deal within a day to possibly a few days and should never come back to haunt you. Don’t get me wrong, there is a myriad of things that can go wrong and many ways that the bond can mess things up. If you have an insurance professional though that knows their way around the bonding and what the TTB is looking for and how to avoid the pitfalls and snares, it really is a one-and-done deal. It really is that simple. Find someone who knows what they are doing and you will not lose any time and it will be the cheapest thing that you purchase for your distillery, hands down. The typical insurance process, step two: You have either acquired a building or are obtaining a lease on a space and there is an insurance requirement. If you are buying a location it may be that the lending institution is requiring that they be named “loss payee/mortgagee” on your insurance as well as possibly “additional insured” status and they want a certificate or evidence stating such. If you are signing a lease, the landlord may have a requirement to be listed as “additional insured” or at the very least require a certificate showing that you have insurance. Again, if you are working with someone who has an understanding of distilleries and has a great product where you can add and subtract coverage’s, this should be a very easy step to accomplish. If you are in a “triple net lease” situation and are required to insure the building, again, it should not be an issue. This is basically all there is to the second step, the securing of insurance for the location and your business. The typical insurance process, step three: You are ordering your equipment and items you will need in order to get set up and running. Once you have a policy put in place to satisfy those items discussed in step two, this is a no-brainer. The equipment and contents side of the policy is one that should be very simple to accomplish. Watch out however as to how these items are listed and what “perils” or coverage is being offered and/or excluded. This is one area where a deeper knowledge of how things work within an insurance policy is key. Someone who knows what they are doing should be able to provide you with a better and lower premium on the equipment than what is available in regards to standard “contents” coverage. Without divulging all my trade secrets here I will simply say that there are a variety of “legal and ethical” tricks that can be used to keep your costs down while actually providing you better coverage. As well, at this time you may be in need of securing many other types of coverage in order to make sure that you are properly insured and protected moving forward. Liquor liability; Cargo coverage; Products and Complete Operations; Workers Compensation; and Product Valuation among many other things may need to be considered at this point. An agent with experience in this arena should be taking the time to discuss your business plan with you. They should find out where you are at currently in regard to your needs and where you see things progressing to anywhere from 6 – 18 months from now. This process will not only assist you with the “realization” of timeframes and considerations, but it will also allow the insurance professional the ability to plan ahead with you or address commonly overlooked insurability issues. Again, watch out for how these coverage’s are written. The product valuation is one of the biggest issues that I see being overlooked. Almost ever carrier in the country uses the same endorsement form to insure your product and for the most part it is very lack-luster. I personally have developed and had adopted an endorsement form that gives true value to your product in the way in which you and I decide it should, not how the insurance company “may” decide to value it. God forbid the unforeseen happens and you lose everything, including your product. That is not the time to ask the question as to how you were insured and what you can expect in the way of coverage. In conclusion, this is a rather simplistic overview of an overall more involved process. With that said though, if you are working with someone that knows what they are doing, it actually can be this easy. A few things to keep in mind: 1.) Know your insurance professional and their background/knowledge. Ask the hard questions, find out how much experience they have in doing this type of work and how many other distilleries they write. YOU DO NOT WANT TO BE THE GUINEA PIG! This is your business, your baby. Treat it as such. If you are not comfortable with their answers, move on. Beware of the agent that says, “Well …… I have written a brewery before. How different could it be?” R U N !!!!! I know I am preaching to the choir, but a breweries and distilleries are VASTLY different in so many ways, and the insurance is certainly one of those ways; 2.) Know what you are purchasing. People have a view of insurance often times that it is just “throwing money down a rat hole”. That it is one of those things that costs a lot of money and they never get anything for it. I understand, but keep this in mind ….. If you know what you are purchasing and the value it brings to you, you will not feel this way. As well, in a perfect world you hope it works out that way. That you pay money in for the whole life of your business and never get anything back from the insurance company. If they have to make a pay out that means that you have either hurt or killed someone or you have sustained an incredible life altering loss to your business. I am not talking about the roof claims or hail type situations, I am talking catastrophic here. If your insurance person makes you full aware of what you are buying, you should never feel as though you are getting ripped off. 3.) Keep in communication with your insurance folks. When you make a change or even better, when you are thinking about fixing to get ready to make a change, give them a call. There may be insurability issues in what you are thinking about. Even if there are no issues, you need to be sure that you have the protection you need to cover the change. Often times the insurance folks are the last to know and that is not good. Loop them in at least every 6 months or each time there is a “big” change coming. 4.) Do it well and do it up front. If you have a good professional that is more a business partner in a way than just an “insurance agent” you should be able to confide in them, tell them exactly what you are doing and what concerns you have. You should not feel like you need to hide anything or not give them all the details. Work with them as you would a CPA or lawyer. They are (or should be, if they are not, run again) a professional and will treat your information with the utmost confidence. Be open an honest and trust them implicitly. If you don’t, why are you doing business with them at all? 5.) **** DO NOT “SHOP IT OUT” **** This is one of those areas that really does not make sense to anyone in the insurance industry. There are people out there that will call 5 different agents and ask them for a quote. They want to “keep everyone honest” and they think by doing so it will ensure they get the best deal if they have multiple people involved. Stop. If you find someone that you are comfortable with that has the background and knowledge and that you trust implicitly, let them shop it for you. Bringing in multiple people only confuses things. Insurance carriers only allow one quote to go out to the first agent in the door. So if you go to five different people they are all going to try to get it out first and block the markets anyway resulting in what you hoped to avoid in the first place. You will then be forced to sign Agent of Record letters to allow other agents to obtain other quotes that some other agent blocked, blah, blah, blah. It is a nightmare for you, the agents and the carriers. Just don’t do it. Pick someone, one agent and work with them exclusively, end of story. I hope this information is helpful and valuable to anyone reading it. The insurance and bonding process should be easy and can even be fun if you get the right person. If you have any further questions or if you view me as being “that person” to assist you with your insurance needs please reach out to me. You can PM me here on the forums, email me at aaron.linden@hubinternational.com or call or text my cell at 307-752-5961. I truly am here to help in any way that I can and I am always happy to answer any questions that you may have. Have a great Memorial Day Weekend! Best, Aaron “InsuranceMan” Linden

Hey ya'll Just taking over the filing of our distillery's TTB forms, and wanted to know what Line 33 of the TTB Monthly Processing Operations means? Withdrawn Tax Determined has numbers for all our previous months, but I'm not sure where our previous distiller was ascertaining this information. Any help would be appreciated. Below is a copy to the TTB form (F5110.28). http://ttb.gov/forms/5000.shtml -Ted

Hey all, I have a couple of questions on the processing report: - Part II: Finished Products, what constitutes a packaged product? - Under part IV C,D,E, and F Do you need to put packaged products in this category as well, or only bottled? If no, is there a location where finished packaged products go? Thanks, Chris 3030 www.threethousandthirty.com

Esteemed Forum Members, I am pleased to announce that I, along with several others, have formed a core group of industry experts in order to better assist those in the craft beverage industry. This team is comprised of a body of experts that have a tried and true historical record assisting those in the craft beverage industry that has proven these members to be the best of the best. We have formed this group in order to positively promote the industry as a whole through best practices, best services, advanced education and unparalleled expertise. Given the incredible rate of growth that the craft distillery industry has experienced and continues to experience, there are a lot of people “jumping in” and trying to take advantage of the rapid expansion in order to make a fast buck. My opinion is that many of these people are diluting the industry as a whole via their lack of knowledge, lack of true understanding, and lack of experience and expertise. Becoming involved only to try and take advantage of a situation and capitalize on it only for personal gain is short sighted and I feel it is also intrinsically wrong. Many seem to be in it only for themselves and in the end only prove to be roadblocks that are a drag on the industry. They are not here to promote the craft distillery industry for the greater good; they are involved only for their own personal wellbeing. Our group of industry experts brings years of dedicated service, specialized products, and a true commitment to the craft beverage industry directly to you. One of the many benefits of this group is that we save you one of your most precious and valuable resources, time! Instead of having to spend countless hours of research trying to figure out who is reputable and who you should chose to work with, you now have a “one-stop-shop” of resources and we offer our services on a national level. While we all remain independent from one another, we work closely together as a group to best assist our clients and service their needs. You as the client though are free however to pick and chose which services you are in need of and can select to use any of us that you like. We are an expert resource group with a working knowledge of one another’s expertise and have an excellent rapport with one another. What this means to you is that if you have questions, we have answers. Our expert group is currently comprised of the following industries: Commercial Insurance / TTB Bonding / State Bonding: Aaron Linden – CIC, www.hublinden.com Product Design / Branding / Marketing: Leif Miltenberger, Hired Guns Creative www.hiredgunscreative.com CPA / Planning: Nick Shepherd & Kevin O’Brien, Irvine & Company, LLC www.irvinecpas.com Legal / Alcohol Compliance: Chris Hermann & Bernard Kipp, Stoel Rives, LLP www.stoel.com TTB Consultant / TTB Compliance: Charles Schumacher Architecture / Design / IFC: Mark Ward, Urbanadd www.urbanadd.com Distillery Operations / Product Development / Consultant: Daniel Feldman, Dodo Distilleries In closing, we are all very excited for this opportunity and the ability to bring our years of expertise and dedicated service to the craft beverage industry to all of you. I would encourage anyone reading this, from the start-ups to those of you who are well established, to reach out to any of us with any questions or comments you may have. The beautiful thing about learning is that no matter if you are new to the industry or if you have been in it for a while, things are always changing and there is always something new to learn. Let us be your resource for learning and let’s positively grow this industry together for a sustainable and successful future.

I had a few questions with the monthly TTB reports: I am a little confused on where to document bulk spirits before they are made into gin. We make vodka first which goes from our production account and then gets deposited into our storage account before bottling. When we need to make some gin we take some of the vodka from our storage tank and then redistill it into gin. Do we show the spirits coming from our storage account back to production for redistillation? How would you show that on the production reports? If that is the case what happens when you make some of your cuts when you redistill it to make gin? You could technically be left with less proof gallons in the end. Or do you keep the gin completely separate from the vodka storage tank and it still is technically in the production account until it is made in gin?