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BigRed    0

We are close to importing our stills and the import agents are requesting bond information. According to the codes, you can have a distilling or rectifying plant for Food and Beverage, or other. If regulated by the FDA, the fee is much higher. Since the TTB and not the FDA regulate the industry, should it be classified as other? 8419.40.0080?

According to the FDA website

Alcohol

The Department of the Treasury’s Alcohol and Tobacco Tax and Trade Bureau (TTB) regulates aspects of alcohol production, importation, wholesale distribution, labeling, and advertising. Consumers may write to TTB at 1310 G St. N.W., Box 12, Washington, DC 20005; telephone (202) 453-2000 or see the TTB Contact page.

 

import codes.png

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Tom Lenerz    12

I could definitely be wrong, but my guess is you are looking at 8419.40.0040. DSPs are regulated by both the TTB and FDA, because they are a food and beverage processing plant. I would imagine other would be for things like fuel ethanol or chemical processing.

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Tom Lenerz    12

http://beverage-master.com/article/when-fda-takes-control-what-alcohol-beverage-companies-need-to-know-about-the-fda/

"In addition to registration, breweries, distilleries, wineries, and other alcohol beverage facilities are subject to FDA inspections. On the domestic level, inspections are usually conducted by state agencies. While this rule is not new either, pre-FSMA alcohol beverage facility inspections were not very common. However, this number is growing what with inspection frequency mandates established by FSMA. Shortly after FSMA’s regulations were implemented, Wine Spectator reported that roughly 261 U.S. wineries were inspected in fiscal year 2011-12 in comparison to 132 in 2009-10. Although FDA inspections may be new to a brewery, distillery, or winery, an establishment that is alert, well managed, and informed should not fear an inspection. During inspection, alcohol beverage facilities are held to current Good Manufacturing Practices (“GMPs”), which are found in 21 CFR Part 110."

The key line here is 'usually conducted by state agencies', so the level of inspection will vary from state to state. 

FDA sets the rules for things like GRAS, three-bay sinks, acceptable materials, etc... Which is then usually enforced by your local health inspector.

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