Jump to content
dhdunbar

Proposed Changes of Standards/ of Fill - this is a major change

Recommended Posts

I am really curious, how distillers in our community feel about this proposed change? I could see how this would allow for greater flexibility and make import/exports easier. However, as a consumer it seems like this would create more confusion in the market with some spirits bottled in 700ml and some bottled in 750ml. According to WhiskyCast the Distilled Spirits Council is currently apposed to the proposal as written. I'd love to hear people's thoughts.

Share this post


Link to post
Share on other sites

It seems like an interesting idea overall. But it will probably be meaningless for me, because state law in Louisiana defines legal sizes. So while TTB may allow new sizes, I doubt the state will enact the same changes. I suspect other states may also regulate permissible sizes, so following the theory of unintended consequences, it might lead to problems with "new" sizes being legal in some states, but not in others.

  • Thanks 1

Share this post


Link to post
Share on other sites

Whose idea was this and how did they determine they should propose it?  

Look at a 40 section.  It' s ot room for x scu's.  If Conglomerate Y has one size for product Z, then product Z takes 2 or three slots depending on turns.  If he has four sizes, that multiplies the number of slot's the product fills.  That favors him over guess who. 

Why are large producers taking a stake in "craft?"  Let me propose, their distributors want a share of the craft market and acquisition gives the conglomerate a brand to fill that need and not just coincidentally the slots that brand takes up.  Retailers get to  have the craft segment they need and they get to deal with fewer reps.  Decisions involve hard work.  A retailer can get both majors and craft with a single sales call.  

Do you think Lay's makes all those different flavored chips because they want to give the consumer choice?  Do you think that is why a major bottler would propose multiple sizes?

Am I correct in this?  Maybe.  Is it the sort of thing that affects most of you?  No, because you are not in that fight anyway.  Would I as a consumer want my milk to come in many different size packages so that I had to calculate the cost per ounce of brand X vs. brand y and size z vs  ....?

  If not, then why would I want that for bourbon?  Why would your customer give a hoot if you package in 700 cl or 750 ml bottles?  You don't want to have to deal with all those sku's either.  The only client who has ever asked me about this was someone who wanted to package moonshine in pint mason jars.  It was the jar perception  that was the objective; not the size. 

 

Share this post


Link to post
Share on other sites

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

  • Thanks 1

Share this post


Link to post
Share on other sites
44 minutes ago, JNorris said:

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? 

I've noticed this same thing. I'm sure some of the big food companies have done market testing to see by what percentage can they reduce the volume of a container before the customer notices they are buying less. 

If the above proposal was just to add 500ml and replace 750ml with 700ml so that the US was in line with the rest of the world that would make some sense but to have no standard fill levels feels seems like it could result in a race to the bottom, but maybe I'm missing something.

Share this post


Link to post
Share on other sites
9 minutes ago, EZdrinking said:

I've noticed this same thing. I'm sure some of the big food companies have done market testing to see by what percentage can they reduce the volume of a container before the customer notices they are buying less. 

If the above proposal was just to add 500ml and replace 750ml with 700ml so that the US was in line with the rest of the world that would make some sense but to have no standard fill levels feels seems like it could result in a race to the bottom, but maybe I'm missing something.

I agree, adding more standards of fill options would be useful, but I would consider more larger options. 3L & 5L would allow for bag-in-box, and 19L & 20L would allow for kegs.

Having a set of standards is important though for sure.

Share this post


Link to post
Share on other sites

TTB can't allow more than one gallon because that limit comes straight from the law.  If you want larger consumer sizes, you will have to get congress to make that change.  TTB cannot do it by regulation alone.  Here is what the law says.  

§206. Bulk sales and bottling

(a) Offenses

It shall be unlawful for any person—

(1) To sell or offer to sell, contract to sell, or otherwise dispose of distilled spirits in bulk except, under regulations of the Secretary of the Treasury, for export or to the following, or to import distilled spirits in bulk except, under such regulations, for sale to or for use by the following: A distiller, rectifier of distilled spirits, person operating a bonded warehouse qualified under the internal-revenue laws or a class 8 bonded warehouse qualified under the customs laws, a winemaker for the fortification of wines, a proprietor of an industrial alcohol plant, or an agency of the United States or any State or political subdivision thereof.

(2) To sell or offer to sell, contract to sell, or otherwise dispose of warehouse receipts for distilled spirits in bulk unless such warehouse receipts require that the warehouseman shall package such distilled spirits, before delivery, in bottles labeled and marked in accordance with law, or deliver such distilled spirits in bulk only to persons to whom it is lawful to sell or otherwise dispose of distilled spirits in bulk.

(3) To bottle distilled spirits unless the bottler is a person to whom it is lawful to sell or otherwise dispose of distilled spirits in bulk.

(b) Penalty

Any person who violates the requirements of this section shall, upon conviction thereof, be fined not more than $5,000 or imprisoned for not more than one year or both, and shall forfeit to the United States all distilled spirits with respect to which the violation occurs and the containers thereof.

(c) "In bulk" defined

The term "in bulk" mean in containers having a capacity in excess of one wine gallon.

Share this post


Link to post
Share on other sites

Create an account or sign in to comment

You need to be a member in order to leave a comment

Create an account

Sign up for a new account in our community. It's easy!

Register a new account

Sign in

Already have an account? Sign in here.

Sign In Now

×
×
  • Create New...