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daveflintstone

selling distilled neutral for non beverage purposes

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If this is already on here please direct me where.

What's the rules/requirements for selling for non beverage purposes?  Like selling to a bitters maker, or to a perfumer, or essential oil producer, whatever, etc.?

I thought I used to know this, but I'm drawing a blank.

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If you are denaturing and then selling you would need to amend your permit to include industrial alcohol and then submit and receive formula approval for the particular denaturing process(es) you are using. Denatured is not subject to FET. If you are selling undenatured and untaxed the purchaser will need an industrial use permit and meet the requirements for tax-free alcohol use.

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I'm talking about selling tax paid undenatured alcohol for the non beverage uses I mentioned.  I know the end user can file for a tax rebate.  But can we ignore any beverage related bottle size requirements?

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Check in with the CFR but a quick search for non-beverage in Part 19 found the following:

§19.626   Records of distilled spirits shipped to manufacturers of nonbeverage products.

(a) General. When a proprietor ships distilled spirits to a manufacturer of nonbeverage products, the proprietor must prepare a record of the shipment, forward the original to the consignee, and retain a copy.

(b) Form of record. The record of shipment referred to in paragraph (a) of this section may consist of either the record of tax determination required by §19.611 or any other document that contains the necessary information specified in paragraph (c) of this section.

(c) Required information. The record of shipment required under this section must contain the following information:

(1) The name, address, and registry number of the proprietor;

(2) The date of shipment;

(3) The name and address of the consignee;

(4) The kind, proof, and quantity of distilled spirits in each container;

(5) The number of shipping containers of each size;

(6) The package identification numbers or serial numbers of the containers;

(7) The serial number of the applicable record of tax determination; and

(8) For distilled spirits containing eligible wine or eligible flavors, the effective tax rate.

From here it looks like quantity of each container needs to be stated but I'm also guessing that means non-standard fills are acceptable. This is just a guess, but would make sense since it isn't for consumer sale.

Additionally you can read through Part 17 covering the drawback process for the client you are selling too, that might have some good information in regards to what you need to provide: https://www.ecfr.gov/cgi-bin/text-idx?SID=a89a1d294d443c17e47b8c7e52c950e1&mc=true&tpl=/ecfrbrowse/Title27/27cfr17_main_02.tpl 

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