winery in distillery

[bluestar]

We want to add a small winery to the distillery. We know that the bonded winery has to show a separation from the bonded distillery, although we know of places where that has been as little as a low fence or even tape on the floor. Anyone with recent experience along these lines? Does the winery have to have access to non-bonded space directly, or can it be through the bonded distillery?

[Northern Waters]

Bluestar - I asked TTB some similar questions about a month ago and below are their responses.  I didn't ask you final question directly but from part of my phone conversation with them we can have a designated space that serves as an alternating premise.  For example you could have a bottling room that serves both the DSP as well as the winery.  So as I interpreted it, part of the DSP could be an alternating premise in which the winery products could pass.  Hope that helps a little.

What kind of separation is required between the winery and distillery?  

 

The separation must be floor to ceiling with no passable access between the two operations  

 

Does it need to be a wall and completely separated space with separate entrances?  

 

Yes, unless the main entrance is into a common general area with separate access from that area into each operations that is lockable from the operations side.

If we were to ferment wine and later distill it, would that have to be transferred to the DSP with the appropriate forms similar to wine transfers between separate entities?  

 

Wine can be transferred from the winery to the distillery, wineries for not have to submit transfer in bond paperwork, but both the winery and the distillery will need to notate their daily records of these transfers.

Are we able to operate under the same entity?  

 

Yes, a single entity can hold multiple permits (both type and location).

Is there anything else unusual beyond the regular winery permit requirements?  

 

There is nothing unusual about this type of winery application, unless both the DSP and the winery will be sharing the same space and the same equipment.  In that case the original winery application would show that they are an alternating proprietor with the DSP as the host and them as the tenant.  If this is the case the DSP will also need to amend their permit for the change to an alternating proprietor with the winery.

[bluestar]

Nice to have more input, but unfortunately it actually confuses things some since it contradicts some of the information obtained elsewhere. I think the confusion is when the winery is an independent entity versus part of an alternating premise. The CFR specifically refers to the possibility of less than physical barriers between wine and spirits when using alternating premise. But the CFR does not speak to separation between distinct premises, and I suspect those must be isolated as you describe.

[RBDistiller]

We have had a winery and distillery operating out of the same space for years, actually had a full running brewery working out of the same space for a while too. Not quite sure how we had the licensing, as that was obtained way before I came here but we didnt go painting lines on the floor to keep things separate. We did have a designated room where the still is located but most of the building was shared. We never had any issues with the TTB and the way we were running the space. 

[bluestar]

I know that setups were approved in years past that the TTB is more stringent about now. In particular, things like separations between brewery and distillery, or winery and distillery, or bonded versus general premises.