Crowlered Cocktails

[Darren Bobby]

Our tasting room wants to begin selling crowlered cocktails filled from pre-batched kegs. We are already selling kegeed cocktails by the glass and there is an SOP for each cocktail.

The question we are trying to find and answer to is do we have to submit those SOPs to the TTB since each crowler will be hand labeled. We are planning on selling 12oz crowlers because we were informed that 32oz was not an approved size for spirits. However, my research has turned up a bar is FL that is selling 32oz crowlered cocktails that are hand labeled. Is it different because that do not have a DSP?

Anyone have any experience in this area? 

Thanks,

[bluestar]

On 2/20/2020 at 2:13 PM, Darren Bobby said:

Our tasting room wants to begin selling crowlered cocktails filled from pre-batched kegs. We are already selling kegeed cocktails by the glass and there is an SOP for each cocktail.

The question we are trying to find and answer to is do we have to submit those SOPs to the TTB since each crowler will be hand labeled. We are planning on selling 12oz crowlers because we were informed that 32oz was not an approved size for spirits. However, my research has turned up a bar is FL that is selling 32oz crowlered cocktails that are hand labeled. Is it different because that do not have a DSP?

Anyone have any experience in this area? 

Thanks,

I think you can only "package" spirits, including cocktails, in a DSP (including rectifier), and it must be in the bonded area, etc. I don't think what the bar is doing in FL is legal. Specifically, the TTB prevents the repackaging of spirits for sale by any distributor or retailer. @dhdunbar, do you know of any exception to that?

[dhdunbar]

This is a swamp full of alligators.  First there is the issue of premixing cocktails.  Mixing spirits is rectification.  That is a word that has been dropped from part 19, which now calls it processing, but it still occurs in part 1, which requires that persons who recitify and bottle spirits haved a basic permit, and in part 31, the liq