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nabtastic

Reuse Glass Bottles?

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I've been asked this several times and I keep shutting it down because I don't want to deal with removing the labels and I feel like there will be a lot of paperwork involved but...

Is anybody reusing their packaging, i.e. glass bottles? This would only be for a few accounts that are concerned with it but I feel like the savings in packaging would be out-weighed by the cost in labor hours. Anyway, if anybody has information about this or can link me to a thread (searched but didn't find anything) I'd be grateful.

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Our glass is actually really expensive (total package cost is over $4). I agree that local health may have an issue but I didn't know if there was anything on the federal level?

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This is a no-no.

27 CFR 31.201 - Refilling of liquor bottles.

§ 31.201 Refilling of liquor bottles.
No person who sells, or offers for sale, distilled spirits, or agent or employee of such person, shall:

(a) Place in any liquor bottle any distilled spirits whatsoever other than those contained in that bottle at the time of closing under the provisions of 26 U.S.C. chapter 51; or

b:

By the addition of any substance whatsoever to any liquor bottle, in any manner alter or increase any portion of the original contents contained in that bottle at the time of closing under the provisions of 26 U.S.C. chapter 51.
(26 U.S.C. 5301)

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Jedd, I believe that is referring to a system similar to how growlers are treated at breweries. I don't mean simply re-capping and re-filling.

That is not what I'm considering. I mean removing the labels, washing, and running through processing again. It would effectively be the same as "buying" new bottles and receiving them again.

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The spirit of the law is clearly to curtail nefarious behaviors associated with cheating taxes, cheating the customer, or cheating both. It's was likely written broadly to eliminate the possibility of loopholes (paging Dunbar!). I can hardly believe that the Federal Government would outright prohibit the recycling of bottles, which is what is being proposed. That said, I wouldn't touch it, for fear that the letter of the law would be enforced (and not the spirit).

How much is really being saved after you take into account the work necessary for receiving, removing labels (probably a disaster), cleaning/sanitizing, relabel and refill, probably new corrugated too. If this account is looking to reduce the cost by recycling bottles, why not package their product in less expensive packaging? After taking into account the labor, you could probably reduce the package costs by nearly the same amount.

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Jedd, I believe that is referring to a system similar to how growlers are treated at breweries. I don't mean simply re-capping and re-filling.

That is not what I'm considering. I mean removing the labels, washing, and running through processing again. It would effectively be the same as "buying" new bottles and receiving them again.

Personally I would go for it. If the labor cost is low, and you can truly say it is cleaned - well then I think you are just fine. At one time here in Iowa a DSP that was giving a $1 refund on one of there bottles because cost so much. They since then switched bottles.Truthfully when a lot of these bottles come over from China how many people wash them out like you would wash off your own spoon or fork? Go for it. It is sad to see these bottles that are so nice get a one time use.

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Personally, I'd prefer to send the bottles to an art school and let them make something fancy...

I'll call up our health department and, code permitting, set up a way to reuse these bottles. I'll let you know if I can find a way to make this not prohibitively expensive. I am not overly optimistic at this point but I'll at least have a definitive answer! Thanks for the comments.

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I tried removing labels and getting the bottles clean enough to reuse again. It ended up not being worth the effort. No product/solvent/cleaner I was able to find removed the label without having to still do a lot of scraping and scrubbing. This is even after having left the bottles soak for days in hot water. Then even once they are free of a label you now have to wash and rinse the bottle numerous times to make sure it is free of any cleaning agent/label remover you used.

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I'd suggest calling your TTB investigator and asking if the CFR citation above applies to recycling. If they say it's ok, get it in writing.

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Hey all,

Quite a few of the MT distilleries re-use their bottles. The issue is Federal, per Jedd's response above. You need to get a letter from the TTB allowing you to reuse your packaging. Once you have that letter, you're good to go, but they do require that you ask and receive permission...otherwise, they're probably willing to throw the book at you.

On the topic of actually doing it, it can be a hassle, but makes good sense, especially if you're pouring from your tasting room. Reuse those bottles saves a lot of money.

However, on the whole, we don't really do it....just too much work.

Cheers,

McKee

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Can't tell you about the legality, but I know Great Lakes Distillery used to reuse their vodka bottles: http://www.jsonline.com/business/120429664.html

Turtle

We still do this and it works out great. We first obtained written permission from the TTB and also verified legality with our state- some states require bars to destroy the bottles. We pick up and buy back (.50ea) from our wholesale accounts and consumers can return their bottles to our tasting room and get $1 in store credit for each bottle. We redesigned our labels and use an adhesive that cleanly comes off with a hot water rinse. We wash in a high temp washer (we discard anything that looks suspect- like bottles that were used for infusions) and have had no issues. I have one part time mom who does the work. We have reworked over 6000 bottles so far this year.

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Okay - the refill provisions to which people are making reference appear in the dealer regulations, part 31. I applaud the actual citation of a regulation, but :

§31.0 Scope.

This part contains the requirements relating to the registration of wholesale and retail dealers in liquors and in beer and to the operations of such dealers, including recordkeeping requirements, prescribed under title 26 of the United States Code. This part also contains provisions relating to entry of dealers' premises and inspection of their records by TTB officers.The prohibition is intended to keep a wholesaler or retailer from putting low price vodka into a bottle labeled as a high priced vodka not that many could tell the difference when mixed (okay, I'm cynical about vodka, but Smirnoff, often malign, kicked high end butt, in a tasting by reportedly sophisticated pallets). It is not designed to keep a DSP from refilling bottles.

The bottle regulations for DSP's are found in part 19.

Sec. 19.511 Bottles authorized.

Each liquor bottle for nonindustrial distilled spirits for domestic use must conform to a bottle size specified in the standards of fill set forth in subpart E of part 5 of this chapter. This rule applies to liquor bottles intended for distribution in both interstate and intrastate commerce.

Two other sections address distinctive bottles and bottles that TB finds might be deceptive as to their contents.

That is is. So I see no prohibition in TTB's rules against a reused bottle. If it satisfied the requirements on the first use, then it should on the second.

However, someone else makes a good point. Don't just accept my statement that it should be of no concern to TTB, no matter how authoritatively I may pretend to speak. When in doubt, WRITE to TTB and ask them to respond in writing about whether you can do it and also ask that they cite the sections of the law or regulation that apply, just to keep them honest. You should get an answer within six months.

The health department may have other ideas, and if you inadvertently leave foreign material in the bottle, say a dead mouse someone stuffed in as a joke, the lawsuit that could follow would tend to render the whole idea ill advised. That, of course, is not legal advice because I'm not qualified to give it. I can, however, suggest that you just recycle the glass so it can be crushed and used in freeways. If it happens to be used in a clogged freeway in a major city it will be further evidence that such bottles pave the way to hell..

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dhdunbar wins the internet of the day!

Grehorst - are you using a standard commercial dishwasher on a sanitary mode or is it a specialty machine? Also, what label company did you use and have you had any problems with labels coming unglued do to heat or other elements?

PBW didn't even attempt to remove the glue. Maybe bleach? I've heard ammonia works but neither sound like a particularly good idea..

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Like some of you gents, we tried recycling. The problems we encountered were: we couldn't get the bottles pristine enough without making the labor cost a joke.

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@Blackheart - that's my concern, that and our on-prem in significantly smaller than our direct sales that it wouldn't even matter. Full insurance for every employee over 20hrs here..

Gotta be a better use for them than tossing them though? Solar panels like the "beer-can effect" in Bio-Dome??

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realized I never finished this thread out.. 

Checked with FDA, TTB, local health department.  Nobody had any issue with it and all seemed to be confused why I was even asking them.. in the end we used some as a "message in a bottle" for visitors and send the rest to recycling.  Cleaning the bottles is a huge PITA without the volume to justify automated equipment.  Thanks for all of your comments and apologies for the delay. 

I believe  27 CFR 31.201 - Refilling of liquor bottles is referring to "marrying" spirits (adding one bottle to top off another) which is unfortunately more common and serious than you might imagine.  Not long ago (2013) there was a "sting" involving a few chains in and around NJ that was refilling super premiums with wells and in a few cases rubbing alcohol. 

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I'm curious why there were so many references to removing the labels? If you place the same product into the bottle again, wouldn't it be better to have writing or label that could survive the cleaning process?

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I'll repeat from my former post.  Distillers can relabel.  If a distiller relabels and the product does not meet the standards of identity, then there is a problem.  Of the distiller relabels with a label for which he does not have label approval, then there is a problem.  But otherwise, the issue of removing labels applies only to wholesalers and retailers, who do not bottle spirits.  

Now, since  wholesalers and retailers do not bottle spirits, any spirits they have come in a bottle filled and labeled by a DSP, or it damned well better come in a bottle filled by a DSP.  

Since the spirits are already in a bottle with a proper label, there should be no reason to put them into a n empty bottle with the same label.  To what end?  

The only reason to pour one bottle into another (well, I guess a retailer could argue consolidation, but that sounds sort of hollow) is to put less expensive products into bottles purporting to be expensive product., soi that they can the public into paying premium prices for goods not marketed as premium.

That is why you have emphasis on relabelling.  And refilling.   

I can't quite refrain from asking a question -  if the consumer can't tell the difference ... okay. I'll refrain.  

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3 hours ago, biodzldan said:

I'm curious why there were so many references to removing the labels? If you place the same product into the bottle again, wouldn't it be better to have writing or label that could survive the cleaning process?

It's highly likely that your labels will be damaged in some manner so you must completely remove and replace.  I do not know of any labels, aside from decorated glass, that will survive customers, in bound/outbound shipping, and repacking. 

Also, many of us produce more than one spirit type/class.  Your label is connected to your formula. 

It's probably better to send the bottles to recycling and start fresh. 

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On 7/5/2017 at 2:47 PM, nabtastic said:

It's highly likely that your labels will be damaged in some manner so you must completely remove and replace.  I do not know of any labels, aside from decorated glass, that will survive customers, in bound/outbound shipping, and repacking. 

Also, many of us produce more than one spirit type/class.  Your label is connected to your formula. 

It's probably better to send the bottles to recycling and start fresh. 

Yes, I was thinking more along the lines of permanent inks directly on the glass. I did some homework on this a while ago, and then shelves to focus on more important matters. 

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