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Found 68 results

  1. Proofing liqueurs: Table 6 question

    I'm trying to proof liqueurs using Table 6 from the gauging manual, but instead of water, I'm using a sugar/water solution. Does the presence of sugar affect the dilution rate? This seems like a common enough scenario that the TTB might address it, but all I see in the gauging manual is for binary solutions of ethanol and water. If the presence of sugar in the diluent renders Table 6 useless, what strategies are people using to dilute alcohol with sugar syrup?
  2. PATH Act and Lower FET rates

    Good Day ADI Forum Members, I wanted to do a post today in regards to the new regulations that have taken effect in regards to the PATH Act and the new lower FET rates that have been implemented and how that may affect your need for a bond. This seems to be a hot topic currently so I thought I would address a few issues here. As you all are aware, the PATH Act and the lower FET rates have kicked into effect for the next two years, and there are many of you that are super excited to cancel or terminate your current DSP bond. Well, let’s just hold on a second and think about what these new changes really mean. In the PATH Act, it was determined that any distillery that has less than $50,000 worth of taxable withdrawal in a year’s time no longer is subject to a bond requirement. Then, the new legislation has gone ahead and lowered the FET from $13.50 per proof gallon down to $2.70. That is wonderful, and a boon for distilleries that will allow for growth, capital investment, the hiring of staff, etc. Both the PATH Act and the reduction of the FET’s are fantastic ……………… HOWEVER ………….. The only item that was really contemplated in the PATH Act was the "Withdrawal" amount; the act never specifically said anything about the operations side of the bond. The operations side of the bond is comprised of the "Distiller / Warehouseman / Processor" portion. This portion of the bond covers for items that you have on hand that is either bottled, in process, being held in totes, or aging/maturing on site. In fact, ALL distilleries still have this exposure being that everyone has product on site in one fashion or another, and many of you have a considerable amount of product warehoused at your facilities. Think about this, if for some reason your product on hand were to be lost, stolen, or hijacked the government could still charge the full amount of taxation that would have been due. Yes, the Federal Government reserves the right to still collect the taxation that WOULD have been collected on that product! Sure, there is a repeal process that you could potentially go through to have the taxation abated or forgiven, but there is no guarantee that the TTB would waive these charges, it is done on a case by case basis. In some instances, the taxes may be due upfront until the repeal process can go through the proper channels, and that process can take a while. Although these situations are rare, they can happen. It is also rare for distilleries to blow up or burn to the ground, but that does not mean that you should not carry insurance. For this reason alone, it may be beneficial to keep your bond in place. If a situation such as this were to occur, and you have cancelled your bond, you would have to come up with the cash to pay for the taxation of the lost product. That could certainly become an issue and cause a lot of heartburn in an already stressful situation. In most cases your federal TTB bond should not be costing you more than a few hundred dollars a year, and that is fairly cheap for your piece of mind. As well, the reduced FET’s are only certain for 2018 and 2019, after that, who knows. It could be determined that the rate will go back to $13.50 or even higher, we don’t know, maybe they will leave it alone forever, God willing. Another potential reason to keep an active bond may be that it is easier to increase an already existing bond than it is to go through the entire bonding process again when you get to a point that you have to have one. If you have a history with a surety company of having a bond in place, it is a fairly easy process to issue a superseding bond to increase the amount needed. If you cancel your current bond, and for some reason your financials are not as strong in the future, obtaining a bond for a higher amount (Operation plus your need for over $50,000 in withdrawal) could be difficult. I do want to be clear, I am not trying to be a “fear-monger”, whether you keep your bond in place or not is a personal preference and I would never "twist" someones arm to keep a bond in place if they did not see the need to have one. I just want to make certain that people are educated in this arena prior to making a decision that could potentially have a severe impact on the businesses you all have worked so hard to build. Also, please keep in mind that having a bond in place is not “free money”. By that I mean, as owner of the bond you are indemnifying yourself to the surety. This means that if the surety has to make payment on your behalf, the surety will make every attempt to collect the funds that they paid out to the TTB. They can seize assets of the distillery, your personal assets, etc. The bond is simply there to make payment on your behalf if you cannot at that time. Sooner or later you will have to reconcile with the surety. If you don’t have a bond in place, you will be reconciling with the government. Either way, eventually you will be paying someone back! The long and the short of it is, just because the taxation rate is less for the next two years, and just because you may not hit $50,000 in withdrawal, you may be money ahead to keep your bond in place, especially in regards to the operations side of things. Just "booze for thought".
  3. Technology Woes

    Dear ADI Forum Members, I wanted to let everyone know that over the weekend my iPhone had a major malfunction and is currently not operating. Apple has been amazing and they are getting a new one to me as fast as they can. However, in the meantime, I do not have access to retrieve any voicemails left at my 307-752-5961 number. If you have recently left me a voicemail on my cell phone please also give me a call at the office at 307-673-2496 (or toll free at 1-800-300-4370), or send me an email at aaron.linden@hubinternational.com . Also, do yourselves a favor out there ....... if you rely heavily on your phone and technology, PLEASE back up your files and have a secondary access point. I remember the day when I knew the phone number for everyone that I would call, and know I don't know any of them. Siri is a great assistant, until she is not there anymore!!!!!!!!! LOL!!!!!
  4. Gin defined

    Spirits with a main characteristic flavor derived from juniper berries produced by distillation or mixing of spirits with juniper berries and other aromatics or extracts derived from these materials and bottled at not less than 40% alcohol by volume (80 proof) The above is from TTB definition. My question is how do you define "main characteristic flavor"? I followed a recipe from the Forum but what I taste most is faint black licorice that I am guessing is coming from a tiny bit of fennel seed I added. Really like the flavor, but is this "gin"?
  5. Gauging, bottling, and tank records

    I just started messing around with the trial version of AlcoDens and realized that you can print the Volume temperature correction worksheet and the blending worksheets. Is anyone using these as their records for meeting TTB gauging, bottling, and tank record keeping requirements. It prints out with date and reference numbers that you can populate. It seems as though this would check the box. I have been trying to find a format that keeps this record keeping as simple as possible, while still adhering to the CFR requirements. AlcoDens seems to cover those requirements with these print outs. Any one doing this or am I missing something? Does the TTB want to see your "work" as far as doing the calculations? This would save me more excel time as i am trying to develop our record keeping procedures.
  6. ALERT! Impending U.S. Government Shutdown could affect access to TTB website Due to the possible impending government shutdown you may have read about in the news, it is possible that access to TTB’s website could be severely restricted or cut off for DSPs while the shutdown is in effect. Therefore, if you need copies of your permits, registrations, formulas, COLAs or other documents that reside on the TTB system, it is advised that distilleries log on and download those items today! Link to TTB Shutdown Plan: https://www.treasury.gov/SitePolicies/Documents/TTB-Shutdown-Plan-12062017.pdf
  7. We have recently experienced some problems when using the standard TTB procedure for determining ABV by lab distillation of liqueurs containing above 30% solids, especially if we have milk solids present. If we start with 100 ml of sample, add 50 ml of rinsing water and then distill off the recommended 96 ml what is left in the boiling flask is so thick that it is impossible to deal with. The actual ABV of the sample is known because we know how much neutral spirit had been added and we know the total volume (from the total mass and measured density). This corresponded very closely with the ABV calculated by AlcoDens LQ, but the lab distillation always gave low results. I suspect this was due to carry over of solids. Even commercial lab results were quite far from the known ABV. We modified the lab distillation procedure and are now getting much more accurate and consistent results, and I would really appreciate your comments if you have experienced similar problems. In our modified procedure we still start with a 100 ml sample but we add 200 ml of water and then distill off 196 ml (which we make up to 200 ml), leaving approximately 100 ml in the boiling flask. This means that the initial solids are still in 100 ml and remain nicely in solution. My calculations show that for a sample containing 15 ABV this procedure will recover +99.99% of the alcohol. Since the alcohol that was initially in 100 ml is now in 200 ml the measured ABV has to be doubled. We understand that this halves the precision of the measurement but the results are so much closer to the known value and are much more consistent - and the glassware is much easier to clean afterwards! How have you gotten around this problem?
  8. There has been some speculation about the new ability to transfer bottled spirits in bond. Yes, it is now allowed. But I want to give a warning; do not be too hasty in making business plans. Wait until TTB issues some regulations. While you will certainly be able to ship and receive bottled spirits in bond, it appears that bottled spirits that you receive in bond will not be eligible for the reduced tax rate unless you either produced or processed the spirits prior to their bottling. That is my reading of the change. I may be reading it wrong, but I think I am right. Yes, TTB does allow a winery that receives bottled wine in bond to remove it at the tax rate (after the small producers credit) that would have applied if the shipping winery had removed it on tax determination for its winery. But the law specifically provides for that. I don't see any such provision in the language attached to the new reduced rates on spirits. For spirits, congress specifically says the rate only applies to spirits produced or processed by the person making the removal. So, if you want to send spirits you have produced or processed to another DSP for bottling, say in 50 ml container or cans, you could do so, and if they returned the packages to you, you could remove them at the rate to which you are eligible at the time of removal. That would appear to be the intent behind the recent changes. It does not appear that congress intends to let a small distilled spirits plant buy spirits in bottles from a large distiller, receive them by transfer in bond, and then remove them at the small distillers rate. I suspect that most of the craft advocates among you will be glad for that. So, my advice is reign-in any enthusiasm you may have for transfering bottled spirits in bond until TTB has its say on the matter. Reply ↓
  9. Just curious if I understand this correctly. Previously I had submitted COLA for all bottle sizes that we make (50, 375, 750 and liter). Does all the information changed between the two meet "allowable changes"? Or do I need a separate cola for each? Just trying to streamline things. Thanks!
  10. Who do you contact at the TTB to let them know that they have a mistake in one of their gauging manuals? I am loading Table 4 into my database and discovered that Wine Gallons Per Pound is incorrect for 173.7 Proof.
  11. Fellow Distillers, We are working on launching our bitters line but running into issues finding out TTB labeling requirements. Has this happened to anybody else? Thank you for your help! Our recipe is finalized, all the ingredients are GRAS, it is unfit for beverage purposes and therefor non-potable. We've gone through the https://www.ttb.gov/ssd/drawbacktutorial.shtml and would like to start designing our labels as we submit. Has anyone found a page where the TTB explicitly states labeling requirements? Is it the same as for regular distilled beverages? Also anybody out there who has successfully submitted do you have to send in a 2oz sample? Thanks Everybody!
  12. Just getting ready to put together our TTB DSP application. I have read many of your horror stories on how long it takes to get the operating permit. I know there are several firms that assist folks like me on crafting and submitting the application. Has anyone used a service like this? Is it worth the money? We're talking $2500 to $3000. But if they can save months of downtime while I'm still having to pay a lease....might be worth it. How daunting is the whole application process? Feedback would be greatly appreciated.
  13. Maybe a bad idea. I"m not an attorney, disregard post.
  14. Who has the answers?

    I am finally ready to file with the TTB for permits. My state (Alaska) has said I can not do anything on the local level to be ready until I get the final approval with the TTB. Is this correct? I have ready a very good post where someone states that you should get everything done at the local/state level FIRST. Has anyone had to go to their state after? I have also been researching companies for bottling and equipment. I have seen tons of compliments on US companies and have settled on Paul at Distillery-Equipment.com should I go US. I have also been looking into several Chinese manufacturers. However, the Chinese companies seem to take forever to get back to me and that worries me a bit. Have anyone had any good experiences with a Chinese manufacturer for their equipment? The company I found for bottling is Rockwood Glass - does anyone here have any experience with them? I tried to do a search in the forum to see if I could view any discussion with their name but did not see a feature to do this. I have no problem putting in the time reading the forums (I cant count the hours in so far). Thought I would see if I got lucky with a response. Software - I have read several posts on the software and I initially thought I would go with Stillhouse, but after reading people that had used Stillhouse AND Whiskey Systems; I got the overall feeling that Whiskey Systems was just as good but less money - if this is incorrect, can someone correct me? Marketing - Where have you found your best ROI has been when trying to tell your town you exist. What local marketing worked best? Where do you think you lost the most money? Has anyone tried Groupon as a way of getting people in; if so which catch worked best ($5 tasting, $10 tour + free tasting, etc?). What sells the best besides the booze? Cups, shot glasses, sweatshirts, t-shirts, hats, etc.? Not sure what to be pre-pared for here. In my state, I can only be open from 9a till 8p; what are the best operating hours in your town? I was thinking a short day 4p-8p for the tasting room (except weekends 11a-8p). We will always have our master distiller there, so if someone walked in - he could technically still help them. Are we cutting ourselves short on the hours? I am just thinking if they REALLY want to check it out, they would come later......I also don't want to kill myself from sitting around all day, when I could be out visiting bars, restaurants, and stores. I was recommended by another distiller to pay for a lawyer to help with the TTB, but when speaking to another distiller a week ago he said he felt that his process was much faster because he was able to get back to the TTB immediately. He thought having a lawyer handle everything could actually delay some things. Overall thoughts? A big thanks to everyone that has posted on here; the community is amazing. I love that everyone shares and they have built such a strong group of educated people. I thoroughly enjoy learning from everyone here. I cant wait to one day be posting and sharing my success for the future.
  15. Change in Control Purgatory

    Hey all, Looking for any and all advice on the pickle we've ended up in. So, I recently bought out all of the shares of a micro-distillery run by a couple and have submitted the amended DSP paperwork for the TTB to approve the change in control of the company. I did this on paper, sending in a ream of documents to the National Revenue Center in Ohio. Because of that approach, I can't check on the progress of the proposed amendments. More importantly, I still cannot get signing authority because the TTB does not recognize me as a legitimate officer in the company yet. This prevents me from applying for COLA's or even paying excise taxes. So far, we've just had to have the previous owner do these things for us, but obviously this is not ideal. He's not involved in the business anymore in an active way and is moving out of state to boot. Anyone have a similar experience or tips or loopholes to getting signing authority faster? Thanks and all the best, Nick
  16. Distillery in Malt Plant

    We are building a malt plant and wish to have a distillery in the same building. Can the malt plant be part of the bonded area? We will be making all malt whiskey. I have searched the TTB site and there is nothing that seems to address this issue.
  17. I (we) are about 98% done with our 1st DSP application, just one more stumbling block...I think. We are going to fall under the new bond requirements: "ELIMINATION OF BOND REQUIREMENTS FOR SMALL BEVERAGE MANUFACTURERS As of January 1, 2017, if you are the proprietor of a brewery, distilled spirits plant, or winery owing not more than $50,000 in excise taxes in the previous year, and you expect to owe not more than $50,000 in excise taxes in the current year on beer, distilled spirits, or wine, you may no longer be required to hold a bond. Please see our Bond and Filing Changes Home Page for more details." However, in the application I see that this TTB Form 5000.18 Change in Bond (Consent of Surety) form keeps populating as a required form. Do I still need to fill this out? Why do I need to fill this out? And if anyone has been in a similar situation how did it go for you, how long did it take? Thanks in advance, cheers.
  18. US Citizen not Born in USA

    Been making a lot of progress with the permit application, almost done and ready to send in. Currently one hiccup. We are an LLC so I am doing all of the OOI's for each person. However, one of the owners is my wife who is a US Citizen but was not born in the USA. She moved here when she was 4 and went through all the proper channels to become a citizen. Current problem is on the OOI form they ask for DOB, City of Birth, State of Birth etc...But they do not have an option for other countries. Anyone run into this or have suggestions? I have reached out to the TTB but right now they are heavily delayed. Thanks in advance Just found answer, I need to choose FR as the state for Foreign, wish all my problems were this easy.
  19. In the process of putting together initial application for DSP. We are 4 partners that have an LLC and in the TTB application there are required documents for each owner/officer. One of these is a Source of Funds SOF. They require a current bank statement and the previous 3 months of bank statements from each partner. I realize we are all going into business together, however, we may not all want each other to see our bank statements. My question - is there a way to provide the info without compromising all this financial data to the other partners? Or has anyone else dealt with this and found a way to keep this private but still meet the TTB requirements? Thanks in advance.
  20. Do I need to submit anything to add a tasting room on to my distillery? I have been operating for over 2 years, and local laws are changing to allow me to now have a tasting room. I know you have to provide that info in the original plans, just didn't know if you had to resubmit.
  21. The TTB permit tutorial states: Did you know that tasting rooms for Distilled Spirits Plants: Cannot be on bonded premises nor can they be on general premises. You must have an area that is completely segregated from the distillery. Any information regarding tasting rooms/retail areas should not be listed in the application information. It should be shown on the diagram so we can ensure sufficient segregation and separate entrances for that area and the distillery. I have attached a basic sketch of my proposed layout for my micro-distillery. I have a 50 gallon tower still and the space I am leasing used to be a micro-brewery, FYI the footprint of the space is 375 SF. It's inside a mill building with other retail units, the space is already up to fire codes with sprinklers etc. However, where I plan to have the still is not separated by a wall. I was curious if the fact that the production area is in one corner away from the tasting if that would meet the TTB demands. Any help on this topic would be greatly appreciated, thanks in advance. layout.pdf
  22. TTB Formula Approvals - Meadowsweet

    Hey everyone, Has anyone ever tried to get a formula approved with the herb Meadowsweet (latin name Filipendula ulmaria)? I'm experiencing a lot of difficulty with my TTB officer at the moment. I know of multiple products that list meadowsweet right on the bottle/label, so I'm curious if anyone has any ideas why they want to deny me use of this herb. I've gone through three rounds of formula corrections all coming back negative. What do you guys think?
  23. I've been looking for a physical copy of 27 CFR Part 30, the TTBs gauging manual. I mostly want one for the tables and ease of use instead of printing tables out and putting them together in a big, clunky binder. Anybody know if these are available anywhere, or if they even exist?
  24. Happy 11/11 everyone!!! It has been a little while since I have posted anything new here on the forums and I thank you all for that based on the fact that ADI members have been keeping me VERY busy with insurance and bonding needs. Speaking of bonds, what a segue into the hot topic of the day. On 11/7/17 the TTB released new information in regards to the "Information for Alcohol Excise Taxpayers and Applicants for Permits and Brewers’ Notices Regarding Internal Revenue Code Amendments Affecting Excise Tax Due Dates and Bond Requirements". Specifically they cite the "Protecting Americans from Tax Hikes Act of 2015 (“the PATH Act”) (Public Law 114-113). Section 332 of the PATH Act amends the Internal Revenue Code of 1986 (IRC) to change excise tax due dates and remove bond requirements for certain eligible taxpayers (see 26 U.S.C. 5061 and 5551)." Are you sleeping yet? Still with me????? OK ............ This bulletin they released specifies new "Excise Tax Due Dates" that basically say that if you were not liable for more than $50,000 of taxable liability for the calendar year prior, and you don't think you will be above that amount this year, then you can pay your taxes on a quarterly basis beginning 1/1/17. That's cool. It also says that if you reasonably (can someone define what that may mean?? "reasonably" according to who???) expect to not be liable for more than $1,000 in taxes this year as well as in the prior year, you can now pay those taxes annually rather than quarterly. No offense here, but if you have less than $1,000 in taxable liability as a distiller, you have to be quite small as that is only about 463 bottles a year, or in other words, just under 40 bottles a month. Ok, on to the "beefier" subject of this information and what you are really wanting to know; who is exempt and no longer needs this pesky bond stuff anyway!??!!?!? Well, staring as of 1/1/17 it says, " ..... taxpayers who pay taxes annually (so anyone paying less than $1,000 a year, my words here, not theirs) or quarterly (so those folks doing less than an $50,000 a year in taxable liability) will be exempt from the requirements to file bonds covering operations or withdrawals of distilled spirits or wines for nonindustrial use, or beer." Based on the fact that taxable liability only comes into play when spirits are withdrawn (yes, in some cases destroyed, but lets not focus on the negative here people) for distribution/sale (not a transfer in bond, I know my stuff), then as long as you will have less than $50,000 in taxable liability you are good to go without a bond. So is this as clear as mud yet!?!?!?! Basically what is being said here is that if you are going to have less than $50,000 in taxable liability this year (and you had less than that last year) you do not have to have a bond any longer. "BONDS!??! WE DON'T NEED NO STINKING BONDS!!!!!!!!!!" WooHoo, right!?!?!? Well ................... not so fast there speedy. There are a few things to consider before making the call to your agent and telling them to cancel that money sucking bond (actually, my bonds are the lowest in the country so they are not "money sucking" at all). First off, are you close to that bond limit of $50,000? If you are close, or expect to be "reasonably" (hahahaha) close, you may want to leave it in place, just in case. You do not want to cancel the bond only to have to turn around a few months or a few quarters later because you have increased your sales/distribution which equates to withdrawal, and now need to be bonded again. Another aspect to consider is this, when does your bond term come due? I have a lot of folks who will fit the requirements to cancel their bond, however their bond terms renew in November or December. According to the stipulations, they need to renew and keep their bond up until 1/1/17, so they MUST renew it. Here is another caveat to that, depending on the surety carrier that issues the bond, the premium may be pro-rated (you can get money back for the unused portion of the term once you cancel) but they may keep a minimum of $100 service fee ............ or ............. if the premium is 100% full earned, you may not get anything back. Well, why cancel the bond at that point?!?!?! The other issue is that the TTB will not allow you to cancel the bond until all unpaid taxes are rectified from 2016. Once they are you can file for a bond exemption with the TTB through the PONL system but they never specify how long that process will take. So here again is something to watch out for. What if your bond term is after the 1/1/17 date and you file for the exemption but it takes them 6 months (for whatever reason) to process it. Do you need to renew your bond while this is in process? At this point in time I would suggest that you do renew it since you do not want to be out of compliance during the processing time. See, this is not as simplistic as it is made to sound. Obviously, these scenarios are all in regards to existing DSP proprietors. So what about new applicants. Well, for new applicants, since the current processing time for a permit is over 200 days, you should be able to apply for your permit and ask for the exemption during the permitting process. That part actually does sound simplistic and appears to be pretty straightforward. There is a first time for everything!!! So what does this all mean, in real facts and figures and how do you know if you will be below the magical $50,000 mark? Well here is a quick mathematical computation for you (keep in mind these numbers are rounded for simplistic purposes): Current excise tax liability = $13.50 per proof gallon (proof gallon defined as 50% ABV or 100 proof) Taxes are only due when spirits leave the plant, so anything in holding/process does not count against this amount Most spirits go out the door at 80 proof, so the tax rate then would be $13.50 x .8 = $10.80 per gallon (since it is proofed down) Therefore, $50,000 / $10.80 = 4,629 gallons a year or roughly 23,000 bottles of booze, or nearly 2,000 bottles a month Here are pretty much the same numbers but done in actual proof gallons (not rounded): $50,000/$13.50 = 3,703.7 p.g. One case of 12-750’s at 80 proof = 1.902 p.g. per case 3703.7 p.g./1.902 p.g = 1,947 cases or 23,364 bottles per year (cases rounded down to full case) 1947/12 = 162.25 cases per month 23,364/12 = 1947 bottles per month So there you have it folks. A long run for a short slide as it were. The just of all of this is that some of you may not need a bond if you are just getting going and some of you may not need a bond even if you are operating, however make sure you understand where you stand and when the bond term comes due before cancelling you bond. As always, if you have any questions please feel free to reach out to me with any questions. I can be reached here on the forums, via email at aaron.linden@hubinternational.com , or give me a call or shoot me a text at 307-752-5961. I am always more than happy to assist you with your bonding questions and do keep in mind ***** I OFFER A FULL LINE OF ALL DISTILLERY INSURANCE NEEDS, AS WELL, I HAVE THE BEST RATES IN THE COUNTRY. ***** Just sayin'. Best, Aaron
  25. case series, series number

    in CFR 19.490 is the "series" product specific for case and/or bottle numbers? If a company has 2 products, A and B, would the first 10 cases/bottles of each follow as product A: 1-10 product B: 11-20 or are both A and B: 1-10 case/bottles? Thanks