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JNorris

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  1. 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
  2. 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.
  3. 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.
  4. 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.
  5. Here is a PDF checklist to aid you in making beneficial comments: https://www.regulations.gov/docs/Tips_For_Submitting_Effective_Comments.pdf and please make comments on all issues that affect you.
  6. Here is a PDF checklist to aid you in making beneficial comments: https://www.regulations.gov/docs/Tips_For_Submitting_Effective_Comments.pdf
  7. Here is a PDF checklist to aid you in making beneficial and pointed comments: https://www.regulations.gov/docs/Tips_For_Submitting_Effective_Comments.pdf
  8. This was a few years ago now and one job ago, but I believe it was .1 or .2.
  9. I called up one of my local scale distributors/companies and asked if they had any used scales that would fit my application. I ended up with a pallet scale, delivered, installed and calibrated for less than $400. Of course, I was around an agricultural area so that probably helped.
  10. Here is what the CFR specifically requires for domestic cases: (a)Mandatory marks. Except for cases marked in accordance with § 19.496, a proprietor must mark in accordance with § 19.483 the following information on each case of spirits filled in processing: (1) Serial number in accordance with § 19.490; (2) Kind of spirits in accordance with the classes and types of spirits set forth in part 5 of this chapter; (3) The distilled spirits plant number where bottled; (4) Date filled; (5) Proof; and (6) Liters or proof gallons. Indy - if you use Whiskey Systems, as noted in another thread, the system generates these labels for you to print on an avery label stock.
  11. "When certain changes occur in ownership, plant, or operations: 27 CFR 19.112 requires that a DSP file an amended registration application on form TTB F 5110.41 or by letterhead notice with NRC permission; and 27 CFR 19.126 requires an amended operating permit on form TTB F 5110.25 Application for Operating Permit (or letterhead notice): Name of proprietor, 27 CFR 19.113 for Registration and 27 CFR 19.128 for Permits; Trade name, 27 CFR 19.129 (Permit only); Stockholders, 27 CFR 19.114 (Registration), 27 CFR 19.130 (Permit); Officers or directors, 27 CFR 19.115 (Registration), 27 CFR 19.131 (Permit); Proprietorship, 27 CFR 19.116 (Registration), 27 CFR 19.132 (Permit); Partnerships, 27 CFR 19.117 (Registration), 27 CFR 19.133 (Permit); Location, 27 CFR 19.118 (Registration), 27 CFR 19.134 (Permit); Premises, 27 CFR 19.119 (Registration only); Operations, 27 CFR 19.120 (Registration), 27 CFR 19.135 (Permit); Production procedure 27 CFR 19.121 (Registration only); or Construction or use of buildings and equipment 27 CFR 19.122 (Registration Only)." § 19.114 Changes in stockholders or persons with interest. The proprietor must notify TTB of any changes in the list of stockholders or persons with interest that was filed with TTB as required by § 19.93. If the change results in a change of control, the proprietor must file form TTB F 5110.41, Registration ofDistilled Spirits Plant, within 30 days of the change. If the change does not cause a change of control, the proprietor: (a) May file a letterhead notice to amend the registration; (b) May file the amended notice on May 1 of each year rather than within 30 days of the change, or on any other date that theappropriate TTB Officer may approve; and (c) Must incorporate all changes submitted by letterhead notice in the next TTB F 5110.41 filed. https://www.law.cornell.edu/cfr/text/27/19.114 Hope this helps.
  12. § 19.484 Marks on packages filled in production or storage. (a)Packages filled in production or storage. Except as otherwise provided in this part, a proprietor must mark packages of spirits filled in production or storage with: (1) The name of the producer, or the producer's trade name, in accordance with paragraph (b) of this section; (2) The distilled spirits plant number of the producer, such as “DSP-KY-708”; (3) The kind of spirits or, in the case of distillates removed under § 19.307, the kind of distillate such as “Grape Distillate” or “Peach Distillate”; (4) The package identification number; (5) “BSA” or “OC” when spirits are treated with caramel (burnt sugar) or oak chips, as the case may be; (6) The rated capacity of the package in gallons shown as “RC-G”; and (7) The name or trade name and the plant number of the packaging proprietor in place of the name or trade name and plant number of the producer if packages of spirits of 190° or more of proof are filled by a proprietor other than the producer. (b)Real or trade names. The producer's or other proprietor's real name, or the authorized trade name used in accordance with§ 19.94 at the time of production, may be placed on any package filled at the time of the production gauge, or at the time of the original packaging of the spirits in wood when, as provided in § 19.305, the spirits were not filled into wooden packages at the time of production gauge. When spirits have been mingled in accordance with § 19.326, the proprietor may use only a producer name associated with any portion of the mingled spirits on packages filled with such mingled spirits. https://www.law.cornell.edu/cfr/text/27/19.484 Hope this helps.
  13. JNorris

    TIB Bottles?

    Gordon - Transfers in bond are only for bulk spirits. Federal excise taxes are accrued/due as soon as bottled product leaves the bonded premise. Once tax is paid on bottles, those bottles can not re-enter a bonded premise.
  14. I have had this same issue before and it was because the stock was too thick, hence it would not roll to the sides of the bottle. It wanted to be flat. We had to change stock for it to work on our bottles. There are so many label companies out there. Find one that does alcohol labels and is close so that shipping does not cost an arm and a leg.
  15. Roger - You can ask that the pending COLA be reviewed be a QC or QA analyst (I don't remember what they call them). I believe I had to send an email to them and ask for a review based off of a prior label approval. Of course, as with any TTB questions, you pose the risk of them coming back with differing answers and then possibly both labels having issues and being rejected. In the email, be nice and detail all of your concerns and specify IDs for both COLAs. Good luck. alfd@ttb.gov
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