Standards of Fill - proposed changes

[will]

I've been unable to locate a reference to proposed changes to the rules or guidelines for standards of fill currently out for comment. Does anyone have a reference to that?

[delaware_phoenix]

Not sure if this is what you're looking for, but the whole of 27 CFR 19 Distilled Spirits Plants regs are up for revision. Much of it is simply reorganization, and standardizing many common variances. It's 105 pages of PDF.

http://edocket.access.gpo.gov/2008/pdf/E8-9095.pdf

Perhaps what you're thinking of is this on page 16 of the PDF file (page 26214 of the Federal Register)

Variations in fill. The current regulation at § 19.386 provides criteria for slight variations in the alcohol content and the fill of bottled distilled spirits that may occur during bottling operations. Acceptable variations in alcohol content (proof) are well defined and very specific in the regulation at § 19.386( b ). However, this is not the case for variations in fill. As stated in § 19.386( b ), the proprietor must rebottle, recondition, or relabel spirits if the bottle contents do not agree with the label, ‘‘except for such variation as may occur in filling conducted in compliance with good commercial practice with an overall objective of maintaining 100 percent fill for spirits bottled.’’ We believe that this criteria could be improved and we propose to establish a standard whereby there must be approximately the same number of overfills and underfills for each lot bottled and in no case may the quantity in a bottle vary by more than plus or minus two percent from the quantity stated on the label. This new clarification appears in the proposed regulation at § 19.356( b ).

If you've bottled 10,000 bottles and see 5 overages, you have to go find 5 corresponding underages.

I have no idea whether the bottles we buy are within the +/- 2% variability in fill or whether according to current GMP bottles are filled with greater variation than 2%.

[will]

Not sure if this is what you're looking for, but the whole of 27 CFR 19 Distilled Spirits Plants regs are up for revision. Much of it is simply reorganization, and standardizing many common variances. It's 105 pages of PDF.

URL = http://edocket.access.gpo.gov/2008/pdf/E8-9095.pdf

Perhaps what you're thinking of is this on page 16 of the PDF file (page 26214 of the Federal Register)

If you've bottled 10,000 bottles and see 5 overages, you have to go find 5 corresponding underages.

I have no idea whether the bottles we buy are within the +/- 2% variability in fill or whether according to current GMP bottles are filled with greater variation than 2%.

Thanks,

As usual, I found it just after I gave up!

same as you said

page 68 of 109 - the regulation rather than the commentary...proposed 27CFR19.600(

compares with present 27CFR19.386

Your bottles are probably within .25oz of 25.36oz or +-1% (for 750's) of volume at a given level of fill. The new regulation is pretty good. The existing regulation says the same thing, but you have to research your a$$ off before you figure it out. Trouble is that without experience, a regulator not based in booze valley might not know that most of the big commercial producers are using fill-to-level equipment rather than fill-by-volume in order to produce bottles that all look the same on the shelf. The new regulation is written to specifically allow this. The old regulation is hopelessly vague. I've heard rumors of TTB agents not located in KY taking our members to task over this simply because they don't know what "filling conducted in compliance with good commercial practice with an overall objective of maintaining 100 percent fill" means.

This deserves a rant....stay tuned.