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JNorris

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JNorris last won the day on June 14 2019

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  1. Thatch - If you still need some help, shoot me an email and I will try to help you with your reports. No sales pitch, just a little assistance. Jennifer@whiskeysystems.com
  2. I mentioned in another post that the TTB was looking at ages in barrels for the new regulations. Here is the TTB response to the proposed regulation: 8. AGE STATEMENTS In Notice No. 176, TTB proposed to incorporate its current policy that only the time in a first oak barrel counts towards the “age” of a distilled spirit. That is, if spirits are aged in more than one oak barrel (for example, if a whisky is aged 2 years in a new charred oak barrel and then placed into a second new charred oak barrel for an additional 6 months), only the time spent in the first barrel is counted in the “age” statement on the label. (See proposed § 5.74(a)(3).) TTB received approximately 50 comments in opposition to the proposal. For example, St. George Spirits stated, “We believe that all time spent in a barrel should be counted towards the spirit's age statement—regardless of movement between barrels.” The Beverage Alcohol Coalition, a coalition of domestic and international distilled spirits industry groups, stated, “It is a common practice for many distilled spirits products, including Scotch Whisky, to mature in more than one type of cask. As proposed, the rule would mean whiskies matured in more than one cask, could not state the full time the product spent maturing, even if the second cask complies with class/type requirements.” Five commenters suggested that if multiple barrels are used, the label should contain an optional or mandatory disclosure of that fact. TTB also received 17 comments supportive of the provision in proposed § 5.74 to eliminate the prohibition on age statements on many classes of distilled spirits, including gin, liqueurs, cordials, cocktails, highballs, bitters, flavored brandy, flavored gin, flavored rum, flavored vodka, flavored whisky, and specialties. Some of the comments specifically noted that they are supportive of expanding the permissibility of an age statement to gin. Three commenters stated that age statements should be permitted on all distilled spirits, including vodka. TTB RESPONSE After reviewing the comments, TTB agrees that all the time spent in all oak containers should count towards the age statement. TTB notes that where a standard of identity requires aging in a particular kind of barrel, such as straight whisky, which requires aging two years in a new charred oak container, that aging must take place in that specified container type before being transferred to another vessel. TTB is amending existing § 5.40(a)(1) regarding statements of age for whisky that does not contain neutral spirits to provide that multiple barrels may be used and to provide that the label may optionally include information about the types of oak containers used. This does not affect current requirements to disclose aging in reused cooperage under 27 CFR 5.40(a)(4). TTB believes that the contemporary consumer understands the meaning of age statements and that there is consumer interest for innovative products such as aged gin. As a result, TTB is amending the regulations in current § 5.40(d) to allow age statements on all distilled spirits except for neutral spirits (other than grain spirits). Because neutral spirits and vodka are intended to be neutral, spirits that are aged would not meet the standard to be labeled as neutral spirits or vodka. A spirit that would otherwise be a neutral spirit but is aged would qualify for the designation “grain spirits,” which may bear age statements as provided in current § 5.40(c).
  3. JNorris

    Fed Tax cut

    Taxes are realized when the bottled product leaves your DSP. As far as your reports go, you should be filing operations reports and excise reports from the day you received your DSP permit from the Feds, even if they are zeros.
  4. To be clear, a lot of wine is made with added sugar. Good wine is not made with added sugar.
  5. Jon - I talk to new distillers all the time about what they should be doing at their distillery. Give me a shout if you have time: Jennifer@whiskeysystems.com
  6. I bought a Master Distillation kit from Pellet Labs: https://pelletlab.com/product/master-distillers-1000ml-distillation-kit/ I have sent so many of my distillers to them that I should be getting some sort of commission, but alas, no. You can also find them on Amazon with free shipping, if you are lucky. You do not need an Anton Paar, the gauging manuals are based on thermometer and hydrometer measurements. Buy a calibrated thermometer and calibrated hydrometers and LEARN HOW TO USE THEM CORRECTLY! Here is a video from Rudolph here as well as the instructions written out on how to to use a distillation apparatus: https://rudolphresearch.com/videos/distillation-obscured-alcohol-products/ BDAS is who I used for samples testing: https://bdastesting.com/ but find someone close to you as you have to pay to ship off your samples. Jennifer
  7. I have done this and seen it done in other distilleries as well. You must have a formula and have label details as to what is in the bottle. You have to be very explicit in your method of manufacture on your formula as to what you are doing to make sure they give you an accurate qualification. My label ended up stating 375mL of whatever spirit, and 375mL of whatever fruit. Be aware this is a 750mL bottle, but only 375mL of taxable alcohol. There are a number of other current COLAs available on the public registry that you can look through for reference, but just because they are approved, does not mean they are accurate. FYI, I did not do this with whiskey.
  8. As one of my distillers said "Processing is the account of no return." Movements out of processing can only be done via a redistillation otherwise spirits will stay there until they are bottled and sold. All adding of ingredients must be done in processing. See below two CFRs regarding flavorings, batch records and accounts. I am no dhdunbar so maybe he can chime in. https://www.law.cornell.edu/cfr/text/27/19.342 § 19.342 Receipt of spirits, wines, and alcoholic flavoring materials for processing. (a)Receipt of bulk spirits. A proprietor may receive bulk spirits into the processing account: (1) From the production or storage account at the same plant; (2) By transfer in bond from another distilled spirits plant; or (3) By withdrawal from customs custody under 26 U.S.C. 5232. (b)Receipt of wines. A proprietor may receive wines into the processing account: (1) From the storage account at the same plant; or (2) By transfer in bond from a bonded wine cellar or another distilled spirits plant. (c)Receipt of spirits returned to bond. A proprietor may receive spirits into the processing account that are returned to bond under the provisions of 26 U.S.C. 5215. (d)Receipt of alcoholic flavoring materials. A proprietor may receive alcoholic flavoring materials into the processing account. (e)Dumping of spirits, wines, and alcoholic flavoring materials. As provided in §§ 19.343 and 19.598, the proprietor must prepare a dump/batch record when spirits, wines, and alcoholic flavoring materials are dumped for use in the processing account. Spirits, wines, and alcoholic flavoring materials that are dumped into the processing account are subject to the following rules: (1) Spirits and wines received in bulk containers or conveyances may be retained in the containers or conveyances in which received until used, but must be recorded as dumped upon receipt; (2) Spirits and wines received by pipeline must be deposited in tanks and recorded as dumped on receipt; and (3)Alcoholic flavoring materials may be retained in the containers in which received or may be transferred to another container if the proprietor marks or otherwise indicates thereon, the full identification of the original container, the date of receipt, and the quantity deposited. Alcoholic flavoring materials and nonalcoholic ingredients will be considered dumped when mixed with spirits or wines. (f)Gauging. A proprietor must determine the proof gallon content of spirits, wines, and alcoholic flavoring materials at the time of dumping. Additional information regarding the gauging of spirits, wines, and alcoholic flavoring materials is found in subpart K of this part. https://www.law.cornell.edu/cfr/text/27/19.343 § 19.343 Use of spirits, wines, and alcoholic flavoring materials. A proprietor must prepare a dump/batch record in accordance with § 19.598 for spirits, wines, alcoholic flavoring materials, and nonalcoholic ingredients used in the manufacture of a distilled spirits product according to the following rules. (a)Dump record. A proprietor must prepare a dump record when spirits, wines, or alcoholic flavoring materials are dumped for use in the manufacture of a distilled spirits product, and when spirits are dumped for redistillation in the processing account. (b)Batch record. A proprietor must prepare a batch record to report: (1) The dumping of spirits that are to be used immediately and in their entirety in preparing a batch of a product manufactured under an approved formula; (2) The use of spirits or wines previously dumped, reported on dump records and retained in tanks or receptacles; or (3) The use of any combination of ingredients under paragraph (b)(1) or paragraph (b)(2) of this section in preparing a batch of product manufactured under an approved formula.
  9. My objection to this is the same as we see in the grocery stores currently, if you have noticed. Many food producers are moving to smaller size packages, incrementally smaller most times, and the prices remain the same. For example (I do not drink milk, so I purchase a lot of orange juice) the standard carton of OJ is 64 oz, or it was a few/ten years ago. They have moved from 64 to 59 oz. AND now have moved from 59 to 52 oz, yet the price remains nearly the same for less volume. How many consumers notice this?? If large producers are allowed to do 700ml instead of 750ml, do you think that they, like food manufactures, will take advantage of the 50ml difference and put those bottles on the shelf for the same price? Have you noticed the package size differences in food and still paid the same price for a smaller package? How many people will run into a liquor store, pick up a bottle, buy it and notice a difference from 750 to 700 ml? How many will look at at the size printed on the bottle label, not many because it looks very similar to what they are used to buying. The TTB is all about protecting the consumer. Will the bottlers take time to notify the consumers of the bottle change? Will they keep both 750 and 700ml bottles on the shelf? Doubtful. Will this create confusion in the marketplace, YES. Will the consumer be affected, YES. So why is this being proposed? Just my opinion, as I am sure that there are MANY reasons as to why this was proposed. Jennifer
  10. While visiting a distillery in Iowa, I saw she used the Whiskey Systems printed barrel labels on paper inside a plastic packing list pouch. They were easy to read and waterproof.
  11. One piece of advice is to make sure your customs broker has dealt with spirits before. AND that they knows that bulk spirits imported to a US distillery does not have to pay taxes as part of the customs and duty charges. This is very important and will save you many a headache, and money, if you do your research on a broker and ask these questions up front before you import anything!
  12. Here is a bit of info from the BAM about ages. While you do not have to store the spirits for a specific time in barrel, you do need to state the time in barrel if under 4 years on the label. FYI, the BAM is only a guide. https://www.ttb.gov/spirits/bam/chapter8.pdf
  13. I did a product in a box where none of the labels were visible. I spoke to the Marketing section of the TTB and was informed that if the brand labels were not visible, then the approved label would need to be on the packaging so that the customer knew what was in the box. That is why so many gift boxes etc. have clear fronts. They may still have an option where you can speak to them about Marketing. It was option 5, but that may have changed. I would call and verify so that you have the info straight from them.
  14. True. They used to have a QA email address where you could send COLAs to someone for them to review, but they have since made it SO much easier to get a hold of them. You know, leave a message and no one ever calls you back and no more email addresses out there, just some contact form that no one ever responds to. I might be able to dig up the email address, but I fear it won't work anymore. Calling and waiting on hold is your best bet.
  15. I was looking further into the CFR changes, and I found this: "Finally, TTB proposes to supersede Revenue Ruling 69-58, which deals with rules for age statements that have been incorporated in the regulations." Which tells us absolutely nothing. Further digging found this: Rev. Ruling 69-58 Advice has been requested whether under the provisions of 27 CFR 5.39(a), a storage statement is required on labels of a non-American type whisky which has been stored in reused cooperage for four years or more. Under the provisions of 27 CFR 5.39(a), an age statement is optional in the case of straight whisky bottled under the Bottling in Bond Act of the United States and foreign or domestic whisky (whether or not mixed or blended but containing no neutral spirits) all of which is four years or more old. The term "age" is defined in 27 CFR 5.10(j) as follows: "Age. 'Age' means the period during which, after distillation and before bottling, distilled spirits have been kept in oak containers, charred if for a whisky of American type other than corn whisky, straight corn whisky, or a blend of straight corn whiskies. In the case of American type whiskies produced on or after July 1, 1936, other than corn whisky, straight corn whiskies, blended corn whisky, and blends of straight corn whisky 'age' means the period during which the whisky has been kept in charred new oak containers." Under the above definition of age, non-American type whisky that has bee stored in oak containers (whether new or reused, charred or uncharred) for four years is four years old. Accordingly, in view of the provisions of 27 CFR 5.39(a) which makes an age statement optional in the case of whisky which is four years or more old, it has been concluded that no age statement of any kind is required to appear on the labels of non-American type whisky (not containing neutral spirits) stored four years or more in reused cooperage. However, if age is stated for such whisky, it must be in the form of a storage statement as required by the last paragraph of 27 CFR 5.39(a). 27 U.S.C. 205; 27 CFR 5.10 (27 CFR 5.11) https://www.ttb.gov/rulings/69-58.htm Here is the proposed change to the CFR: § 5.74 Statements of age, storage, and percentage. (a) General. (1) As defined in § 5.1, age is the length of time during which, after distillation and before bottling, the distilled spirits have been stored in oak barrels in such a manner that chemical changes take place as a result of direct contact with the wood. For bourbon whisky, rye whisky, wheat whisky, malt whisky, or rye malt whisky, and straight whiskies other than straight corn whisky, aging must occur in charred new oak barrels. (2) If an age statement is used, it is permissible to understate the age of a product, but overstatements of age are prohibited. However, the age statement may not conflict with the standard of identity, if aging is required as part of the standard of identity. For example, the standard of identity for straight rye whisky requires that the whisky be aged for a minimum of 2 years, so the age statement “Aged 1 year,” would be prohibited, even if the spirits were actually aged for more than 2 years, because it is inconsistent with the standard of identity. (3) If spirits are aged in more than one oak barrel (for example, if a whisky is aged 2 years in a new charred oak barrel and then placed into a second new charred oak barrel for an additional 6 months,) only the time spent in the first barrel is counted towards the “age.” There is a lot more to this new CFR, but I am checking to make sure that the above in red is a new proposed change and that this is currently not in the regulations for barrel aging.
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