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Stainless steel barrels for temporary holding tanks

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Filling out the last part of the TTB online permits form. Opening a small craft distillery in Ashville, Ohio. We are going to use 55 gallon stainless steel barrels for fermentation, holding tanks prior to going into oak barrels and for some of the aging. Do they need to be registered with a serial numbers with the TTB? And if they do, can I number them after they are acquired?



M&O Spirits, 


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You do not need to include, in the equipment list, any portable bulk containers having a capacity of less than 101 gallons.

Sec. 19.75  Major equipment - As required by Sec. 19.73(a)(9), the application for registration must include a list of the major plant equipment. If the equipment is set up and used for the production, storage, or processing of distilled spirits, wine, denatured spirits, or articles, the list must provide the following information:

    (a) The serial number and capacity of each tank in the plant. The list does not need to include any bulk containers having a capacity of less than 101 wine gallons on the plant premises if those containers do not meet the criteria of a tank under Sec. 19.182 (perks, small totes, etc.).  

The only problem with that is that 19.182 does not contain criteria for determining if something as a tank.  It contains requirements for how you must equip a tank if you have a tank, but it does not say what a tank is.  


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