bluestar

TTB sees everything the same, except for the special experimental permit. But you can't drink the results of that. And you have to pay tax on whatever you make even if you consume it yourself, etc., even if your state allows limited production for self consumption. The TTB does not recognize that as being different than commercial production. The TTB doesn't charge for the license, they tax the product. The state may charge for their permit. And you have to check with the locals as well. In other words, there is no less work to set up a 10 gallon still than to set up a 100 gallon still: same paperwork and requirements for the TTB. The intent is to specifically prevent hobby distilling, ever since prohibition.

I am trying to make a decision on buying a system: do I buy a plate or a cartridge?

See my other thread on Gin formulation in the Gin area. My most recent correspondence from the TTB (quoted there) states definitively that distilled versus redistilled is precisely whether there is one or more distillations from the mash, as the original post (Nick Jones) suggested. I know that is not consistent with other info obtained from TTB nor with how many currently submit to COLA. And I don't think it makes any historical sense either, since I believe the formulation requirement IS NOT driven by review or determination of botanicals (other than juniper dominance) since that was historically an FDA issue. Rather, I think it may have derived from the concern for "adulteration" or masking poor quality of gin products by a blender or rectifier, versus product of a distiller. If so, then the interpretation suggested by Hawk would be appropriate. I think there is enough confusion on this topic that the TTB really should issue a clarifying statement or bulletin.

I thought I would ping this question again, but broaden it: any comments on the efficacy, convenience, and cost of using cartridge versus plate and frame filtration systems, whether for particulate or carbon filtration?

It should be OK if you are not compounding. All of the botanical contributions should be volatiles in a distilled gin. Avoid carbon, though, which would strip out some of the organics.

Another data point from the TTB: "The regulations do not address the issue as to when the botanicals are added, but rather how many times the product is distilled." In other words, if the mash is distilled once, it is distilled gin. If the mash is distilled more than once, it is redistilled gin. I did get clarification that adding tails to mash does not change anything. Which means there could be a fairly absurd result: you could add a large amount of tails from a large mash run to a small amount of mash, and distill it, and it would not be redistilled. I have the suspicion that somehow, over the years, the meaning of these categories has become confused. I suspect that the original idea was to separate those who were doing rectification (compounding or redistilling, starting with someone else's spirits) from original distillation (regardless how many times it ran through the still). That would explain why a formulation is required for the first two, but not for the latter. And why would running three time through a pot still be treated differently from someone running through a continuous still?

Actually, that should be http://www.artisanstilldesign.com I think.

Same for us. Where I have seen the separation by a line (actually a picket fence) is where the bonded area is inside another manufacturing area, in this case a brewery, that is otherwise secured from the public: Michigan Brewing.

Actually, I think that last comment could be misleading. While it is true that bonded and general premises can be separated that way, it all depends on what is done in the general premises and how everything is secured. The primary consideration will be the security of the revenue, and since access of the general public in normal course of business to the bonded area could be considered a security issue, I doubt you could have the tasting room not separated from the bonded area if it is a publicly accessible tasting room.

I thought I would share the most recent (clear) statement I received from someone in spirits formulation at TTB: My question: "But my understanding is that it is common practice to first distill mash to low wines before adding the botanicals, and then to distill this mixture of low wines and botanicals to produce gin. If the mash distillation and low wine distillation are both conducted in our distillery, would this still be a Distilled Gin and would this still not require a formulation review before COLA?" The answer: "If the gin is produced as described, it would be considered a redistilled gin since it the botanicals are added to spirits and not to the mash. As such, it would require formula approval." Just another data point, YMMV.

Ugh, international trademark issues. Just think Budweiser.

Curtis, are you decrying the original decision for MM, or that the appeal is going forward? I think the original ruling was too broad, so I was pleased to here there is an appeal underway.

Chuck, could you point us to Lew's article?

Bad link. Try here: http://itunes.apple.com/us/podcast/the-speakeasy/id428499961 It is the most recent entry right now, Episode 47.

Glencairn will do it for you when you purchase the glasses wholesale from them, which seemed to be the most cost effective way I found so far.

Not until their patents expire (quartz u-tube and ancillary). I did see an asian alternative being used at one small distiller, but it did not seem anywhere as easy to use, but I haven't followed up. He had just started using it. I use APs handheld for non-tax measuring as most do.

Not quite full disclosure: where in the Midwest. That is a very big place, and there may be many in the midwest that might not consider you competition because they are one or two states away. Or there could be someone in an adjacent state not in the nominal midwest that would consider you competition.

Grabbed, and while I was at it, finally added your Bourbon book to my library, thanks.

Not all Anton Paar's can be used for final proofing. The portable units, as nice as they are to use, do not provide the required accuracy. I have had detailed correspondence on this with TTB. They have no current official approved list of current models, but they will tell you the Anton Paar 5000 is used by their laboratory. On the other hand, this is spec'd far beyond the legal requirement. If you go by Anton Paar's specs, the 4500 and 4000 benchtop models should also meet the requirement. Unless you exactly follow the gauging manual with classic calibrated hydrometers, however, you use them at your own risk. The same could be said of any recent asian densitometer that functions similarly to the Anton Paar (but different enough to avoid patent infringement). I don't know this for a fact, but I suspect on reason the TTB won't yet make statements on these is because there is no real competition, and they don't want to endorse a specific vendor. Also, even if you could use the 4000, it is frustrating that Anton Paar won't sell a model of a hand held with 2x the precision and accuracy, to meet TTB requirements. Honestly, it is probably just a change in the programming of the device. Again, lack of competition may be the issue. JMO

You can do it in Illinois and Michigan. In Illinois, it is may be called a tasting room, but as long as the local ordinance allows, it can act as both a full bar and a retail shop so long as you are only selling your own product. I don't think that Illinois restricts you from selling food stuff on premises, and so I presume it could be an on site restaurant. However, to date, I am only aware of tasting room set ups. Our tasting room will be a small bar. In Michigan, it specifically allows for ownership or co-ownership or other ownership of a restaurant on premise. The license is based on the small winery license there. New Holland is in the same building as their brewpub, Michigan Brewery in on site with their brewpub, and Journeyman has a full bar running on site and could expand to a restaurant, but they all should speak for themselves on the details.

Has anyone tried using the activate carbon fiber (not granules) filter cartridges? Seems that in a 30cm single or triple it should be easier to use than a 20cm x 20cm plate and frame system. Also looks cheaper to start up?

This looks great! Has anyone looked at this and found something negative compared to the original reporting forms?

This can be tricky, because I think the interpretation is left to the locals. Similar problem exists regarding bottled spirits. They do count toward the storage total in the F1 area, because the exemption for bottled spirits only applies to a mercantile or M occupancy. But F1 and M occupancies can exist in the same building and may exist in some cases without barriers. But the barrel exemption I think is different, because I think it is specifically called out as an exemption to the 120/240 gallon total without reference to a specific occupancy requirement, I think?

From the state point-of-view, I think Michigan. I am setting up in Illinois right now, and I have good local support, but the state and county requirements are real and the costs are far higher than Michigan. On the other hand, it was hard to get good local support where we had been working in Michigan. But that will vary from locale to locale, I expect. Illinois is not bad, right now, compared to many others, with its new craft distillery permit: you have on site sales for on and off premise consumption, and while other sales are through the tiered distributorships, there are a few distributors you can work with. But permit costs are high: basic permit is $1800/yr in Illinois compared to $100/yr in Michigan!

I think it would be a disaster. IRS is a far less navigable agency than the TTB. And the FDA? Really? You want to talk glacial? RIght now the TTB is as responsive as it is because it is motivated to make decisions on your products, etc., in order to generate revenue, its primary focus. If those functions are separated, the FDA would be only focused on preventing things from moving forward and IRS on punishing you for making mistakes. Think about it.