"Be A Distiller" program?

[Huffy2k]

I've been noticing a number of local brewers offering a brew your own beer program and it's gotten me to thinking about starting a "Be your own distiller" program at our distillery.  We have a 15 gallon still that we use internally for R&D and recipe development and I thought that would be a good platform for this program.  My initial thoughts would be to offer this as a several month long program where the customer will have an opportunity to actively participate in all phases of creating their own spirit.  From recipe development, grain selection and grinding to mashing, label design, fermenting, distilling, proofing, barreling and bottling to taking home your empty barrel along with a couple bottles of your custom made spirit.  While this won't be a huge money maker given the limited capacity of our R&D still, I think it would be a great way to create ambassadors for our distillery and allow spirit geeks to really experience the process involved in distillation.

I'm wondering if anybody else out there has done a similar program and what, if any, legalities/roadblocks I need to consider before jumping into this.  Thanks!

[TylerPederson]

Heritage Distilling is doing that here in Washington. http://heritagedistilling.com/product/mybatch/   It's not an easy type of program to implement, as I think they have probably had more TTB audits than most of us combined. 

[dhdunbar]

I won't go into details, but you have to be the distiller.  You can't turn your equipment over to the person who wants to have spirits made and you probably would not want to do that anyway, for liability reasons. Remember that no one except a DSP can make spirits.  There's no personal or family allowance.

I don't know of any guidelines for distill your own programs.  Here's what TTB says, in FAQ's,  about brew your own operations at a brewery:,

2. TTB Brewers Operating BOPs 
Under some circumstances, a TTB qualified brewery may operate a BOP. All beer produced at a BOP on brewery premises is taxable under Federal law, must be labeled in accordance to 27 CFR part 25, must bear the Government Warning Statement required under 27 CFR part 16, and is subject to recordkeeping and other requirements.

For further information regarding qualification of a brewery or operation of a BOP at a brewery, contact the Brewery Applications Section at the National Revenue Center, Alcohol and Tobacco Tax and Trade Bureau, 550 Main Street, Room 8002, Cincinnati, OH 45202, or by:

Telephone (toll free): (877) 882-3277
Fax: (202) 453-2978
E-mail: TTBInternetQuestions@ttb.gov
n.Last reviewed/updated: 03/13/2015

TTB says only under some circumstances.  It doesn't specify the circumstances.  You are going to have to ask TTB.  And brewery and spirits are not analogous.

Good luck.

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[Huffy2k]

Thanks Mr Dunbar! Yes,  we will definitely be running all the equipment,  the customer will only be a semi active participant (i.e. turn that knob 3 turns clockwise,  etc). I would absolutely intend to keep detailed records for TTB reporting and submit labels to COLA for approval.  I will definitely follow up with TTB to get their blessing before I do anything in regards to this idea. 

 

Thanks!