Barrel Labeling

[Patio29Dadio]

What are distillers using to label their barrels in the barrel room? 

We are using a marker.  Thinking we might need a stamp.   Or maybe a printed form in a plastic pouch. 

[kleclerc77]

I like using big sidewalk chalk, or a grease marker. 

[JNorris]

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.

[Tom Lenerz]

We sharpie the head with the number, and then print a cardstock label with all the details from whiskey systems and staple that on. If the barrel gets wet, we can always reprint the label as the number is still on it.

[Classick]

I have been printing stickers with the pertinent information on the rack underneath the barrels, then covering the stickers with clear tape to protect.

probably not strictly legal, but when using reused barrels that already have info printed on the heads, there's not much room for new info. hopefully any auditor would see we're making best effort

[bluestar]

15 hours ago, Classick said:

I have been printing stickers with the pertinent information on the rack underneath the barrels, then covering the stickers with clear tape to protect.

probably not strictly legal, but when using reused barrels that already have info printed on the heads, there's not much room for new info. hopefully any auditor would see we're making best effort

I think if you got inspected you would be dinged for that, and asked to fix it.

[Classick]

3 hours ago, bluestar said:

I think if you got inspected you would be dinged for that, and asked to fix it.

maybe so...  cross that bridge when we come to it

[bluestar]

On 6/16/2019 at 12:21 PM, Classick said:

maybe so...  cross that bridge when we come to it

Just keep in mind, if they find an error like that, they could just say "fix it", but they could also say: we estimate the following potential errors in tax determination could result from lacking legally required numbers on the barrel, so we will charge you all possible back taxes plus fines. Just doesn't seem like it's worth the trouble, when you could just staple a label on the barrel.

[dhdunbar]

I'll try to get this into perspective before tings spin out of control. 

 

You are required to put two kinds of marks on a barrel.  One is the lot identification number.   The lot identification number ties the barrel to the package record and the package record ties it to the package gauge record.  Any number of barrels of the same product filled to the same fill on the same day can have the same lot identification number.   See §19.485.  the lot identification number is a coded number.  If you don't have a number that looks like this, "02A02B," which translates as this is from the 3rd lot filled in on 1/2/2002.  You are supposed to follow that code.  

Next,  §19.483(b) and (c) provide that you  may use labels as the means for applying prescribed marks if the labels meet the requirements of paragraph (a) of that section (they have to be legible, etc).  A proprietor must place the prescribed marks on one side of the case or encased container, or on the head of the package.

Now, in addition to the lot identification number I'm sure you are all usng,  §19.484 requires a bunch more information and  §19.486 requires still more if you repackage the product into another container. 

But none of this establishes a tax liability and TTB can't assess taxes on the mere prospect that something may have escaped the system.  They need to prove the liability; you need to prove the deductions, or, in the case of excise taxes on spirits, prove that any quantities to which the tax has attached, and which were not withdrawn on determination of tax, are accounted for in ways that demonstrate tax was not due.

TTB can suspend permits, or collect offers in compromise, or even fine you, if they can find a US Attorney willing to take such a case into federal court, which is not going to happen unless the omission of markings is a part of a fraud that has far more serious consequences. 

However, Bluestar is correct.  If your records don't allow TTB to trace the spirits through the system, AND you can't account for what you are liable, then there is a potential for an assessment on the quantities for which you can't account. Even tough that requires a lot more than leaving a label off a barrel, there is no reason not to affix the label with the staples Bluestar suggests. 

Hoochware alos prints labels, so most database systems probably do.    But you can do it with the permanent marker on a piece of paper you attach with staples.  

 

   

[Classick]

14 minutes ago, dhdunbar said:

If your records don't allow TTB to trace the spirits through the system, AND you can't account for what you are liable, then there is a potential for an assessment on the quantities for which you can't account.

And this is why im not too worried, because i can trace all the barrels, to all the gauge records and package records. I can account for each drop, which ,i'd think, is really what they care about.

Still, it had not occurred to me to staple labels to the barrels.. the only reason I've done it how i have was because all attempts to affix paper labels to parts of the barrels have failed I think I will give staples a try, since my barrel heads are already pretty crowded with jack daniels identification information

Thanks for all that info though! much appreciated 

[bluestar]

17 hours ago, Classick said:

Still, it had not occurred to me to staple labels to the barrels.. the only reason I've done it how i have was because all attempts to affix paper labels to parts of the barrels have failed I think I will give staples a try, since my barrel heads are already pretty crowded with jack daniels identification information

Thanks for all that info though! much appreciated 

Also, you can not have misleading or incorrect labeling information on the barrel. For example, you can't have another distilleries information on the barrel and not indicate it is out of date and replace it with your own. Otherwise, the TTB would be in its rights to presume the legacy markings on the barrel ARE the correct labeling of the barrel, and hijinks would ensue. You should at a minimum cross out prior dates and batch/serial numbers with a marker, if you are not doing that already.

[Classick]

I hadnt thought about that either... given these are used bourbon barrels... what do you guys do? use a sander and sand off the previous DSP information?

[bluestar]

22 minutes ago, Classick said:

I hadnt thought about that either... given these are used bourbon barrels... what do you guys do? use a sander and sand off the previous DSP information?

Draw a marker through it. Paste/staple a label over it. Some distillers actually paint out the whole head of a used barrel (use something acceptable for food grade, wineries sometimes use whitewash) and then relabel over that. Some will just cross bad info out, and switch to the other head for new labeling.