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Curt

Special application or permit for GNS when applying for DSP

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Does anyone have any knowledge of a specific part of the DSP application process that is specifically related to GNS or NGS? One of our owners spoke with a gentlemen during a distillery tour and he mentioned something about a specific permit from the feds when using GNS. I talked  with a rep from the TTB today, and she didn't seem to be aware of this, and mentioned that if using GNS as well as mashing from scratch (we plan to use both techniques at different stages), that we may have to apply for the permit as both a beverage and an industrial permit?

Does that sound right? Does anyone have an answer for this or some insight? It doesn't seem to make a whole lot of sense that we would need to apply as an for an industrial permit if we are simply purchasing GNS and then making GIN by running it through our stills with the additives.

Any help would be much appreciated.

Cheers,

Curt

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I think you were given two wrong pieces of information. Your state might have some weird alcohol permit requirement but I don't believe the TTB makes a distinction. You will need a transfer in bond form filed with TTB for anything brought in from another DSP. Maybe that is what the guy on the tour meant?

 

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Thanks kk,

This makes a lot more sense now. I found the form you mentioned as TTB 5100.16. We would just fill this out with the GNS provider and submit to TTB after receiving our DSP.

Much appreciated,

Curt

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Conversations go in weird ways.  GNS, by which I assume you mean grain neutral spirits, is GNS, whether you buy it from a supplier or distill it yourself.  You must consider two things.  First, the use to which you put neutral spirit determines if the spirits are industrial or nonindustrial (beverage) alcohol.  Second, beverage spirits may only be distilled, warehoused, and processed by persons who hold basic permits as producers or processors of beverage spirits.  As a result, you may not buy GNS for use in beverage products if the alcohol was not distilled by someone who is authorized to disitll  beverage alcohol, .i.e, someone who holds a basic permit in addition to the plant registration.  If the neutral spirits were produced as beverage alcohol,  whether you buy the neutral spirits or distill them yourself is of no consequence to your use of them to manufacture beverage alcohol products.  

However, it will affect label statements, which is probably why you want to redistill it rather than simply using charcoal filtration.  

KKBodine is correct.  You will need a special "permit" to receive spirits in bond.  You make application to TTB to receive spirits from a specific supplier and TTB approves the receipt of spirits from that supplier.   Four suppliers?  Four separate applications and four separate approvals.  But the permit is good for repeated transfers.  

You may apply for transfers in bond when you apply to register the DSP and for your basic permit.  You do not have to wait until you have your permit, at least if you use permits on line and do use permits on line for about 32 reasons on which I do not wish to elaborate here.  TTB will not authorize the transfer until you have a DSP.

I don't have time to cite the sources, but don't let TTB get away with statements like, "{You may need ..." Tell them to cite a source that you can read for yourself.  I'm busy now, or I would do that.  You should not rely on what I say, or anyone else says, unless I or they or TTB can tell you how they reach the conclusion.  

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Thanks dh. So just to clarify... If we are permitted beverage, and we intend to make only beverage spirits, we need to purchase and register with a producer of GNS who has beverage permitting.   Not someone selling GNS with an industrial permit.

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That is correct.  You want to deal with someone who can supply you with both beverage alcohol and a basic permit number.  That is not the DSP number.  The DSP number, in the format DSP-HI-20015 (I can dream about being in Hawaii, right) is not the basic permit number.  The basic permit number will be of the form HI-S-20163.  You can check TTB's website for a list of persons who hold basic permits for beverage alcohol.  

I have seen some industrial suppliers insist that they can sell to beverage producers.  TTB says no.  To get around the arguments that follow from citation of regulation, here is the wording of the second instruction on the Form 5100.16 (paper format):

"In-bond shipments must be authorized transfers. For example, industrial (nonbeverage) spirits may not be transferred to a plant whose permitted operations are solely non-industrial (beverage)."

That is definitive to my mind.  It seems not to be definitive to some suppliers of bulk spirits.  The supplier may insist it don't need no stinking  basic permit, but the supplier does need a stinking basic permit to produce beverage alcohol.  And it may not ship industrial alcohol to you unless you are qualified to receive industrial alcohol.

 

 

 

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