bluestar

Not impossible if distillery only, and barrel, grain, and bottle storage off site, and still (hence fermenters) are small (<60 gallon). But that gives you no space for sales room, which CAN NOT be in the bonded premise. I presume because you note the foot traffic, this will be your sales location. Can't discuss remote tasting room possibility, because you did not indicate which state you are in (state permit governs this).

Yes, alternating premises are dealt with in the CFR. Michigan also allows it. You have to submit paperwork each time your alternate. It specifically applies to the bonded premise. On the other hand, tasting rooms, sales rooms, etc., are governed only by the Michigan law, and that might not allowed shared space. When I looked at sharing with a winery, for example, we had to have separate tasting/sales space, although they could be in the same building, we think. We never followed through.

Correct, and what everyone has been trying to tell you is that there are no specific requirements for most of these trace congeners in the US. Noone is disputing they don't affect flavor, just pointing out they are not regulated by the TTB. If you want anything more specific, talk to the TTB.

I suppose the assumption is that if you make vodka per the US standard, by distillation to greater than 190 proof and subsequent (diluted) filtration (usually in charcoal), there is unlikely to be very much of anything left in the vodka but alcohol and water. European standard of vodka is very different, you can have significant amount of congeners in the product. But not in the US, or at least, not easily.

No, that is not illegal, because it is being done under a DSP permit. That's the point: you need a permit, and must meet all the laws, to make any spirit based beverage that will be stored for any length of time, other than preparation just prior to service.

Yes, I am talking about regular licorice root. Unless the powdered licorice root has a sweetener added (and some commercial versions do), licorice does not taste very sweet on its own. If you chew licorice root, initially it is very bitter. After a while, the characteristic licorice flavor appears, and a sweetness can be perceived, and then a numbing. The source of the sweetness is the compound glycyrrhizin, which is nominally fifty times sweeter than sugar, but the perception of the sweetness is more of an aftertaste that is not immediately there, but lingers long after exposure. Unfortunately, glycyrrhizic acid is also toxic, and is the reason why licorice consumption is limited, as well as the quantity that can be put into spirits. You can get high concentrations of oils from anise and fennel to make a fairly sweet spirit, but you should not impart high concentrations of licorice or you may exceed limits for glycyrrhizic acid. Peoples perception of the sweetness of licorice root vary, mostly likely a genetic predisposition. We do use licorice root in our gin to provide a bittersweet aftertaste. It is more likely to be perceived after finishing a sip, rather than while drinking, we find.

Licorice is a good flavor for a sweetened spirit, but is not sweet itself. In fact, it is a bitter, which is why in formulas that use licorice, you may need to add sugar. This is different than anise or star anise, both which tend to perceptually sweeten the spirit, even without sugar.

Did you have a clean room for bottling? Did that come up?

unless something on your label suggested it required a formula, that is, took it outside of the standard. or you didn't classify it correctly. or who knows? first thing you do in this situation is call them. mistakes also happen, and they usually try to correct them.

The bonded premise MUST be controlled access to protect revenue (see CFR). But if you pass through a restaurant to get to the bonded area, for example, it but must be under your control (ownership, leasehold, operation). And no public access into or through the bonded premise or general premise is allowed (for access to bathroom or fire door required by code, for example). But as to fire hazard zones, depends on local interpretation, depends on the building, and is a separate question. Our bonded area is F1, and the other areas B or A, but the entire building is a single zone, so fire separations are not required.

Closed storage VESSEL or SYSTEM not area, just to be clear (can't be open storage vessels in a closed area, for example).

Copper salts in final product is one of the reasons some of us choose to avoid the use of copper condensers and parrots. That doesn't mean you can't make good, safe spirits with copper downstream of the still head, just that it does make one more thing you would have to monitor and control.

Also, I have worked with liquor lawyers briefly in two states, and in the end have had to do much of the research myself.

what is the diaphragm or any other wetted materials, beyond the SS?

Bottle at Navy Strength!

Tell the truth: how much is the maximum that can be stored according to your PLANNED operations, it is the same question you have to tell your bond underwriter, give the same answer. It is NOT asking you how much you are bonded for (although they must be consistent in the end).

The state also matters, very often it is their implementation of the tier and no-tie laws that partially govern the TTB requirements relevant to things like direct sales to retail, including in barrel. So you need to get a lawyer for your state.

all of the above, very dependent on your process

The latter case would probably be warehousing, technically. I am still not sure that you can do that for someone who is unlicensed. Time to check the CFR, but it sounds like something they would prevent. Otherwise a mob boss could own the entire contents of a rickhouse.

A future is a contract, not a direct ownership. It is a contract to own. So, until delivered, the item belongs to the DSP. The future states that the purchaser has rights to receive that item when released. I believe most barrel pre-purchase schemes are actually futures. That was how it was done when everyone was buying scotch in Scotland.

Below detectable limit, which is currently 10PPM

The Illinois Craft Distillers Association was recently formed as a 501©6 corporation in the state of Illinois. The ICDA will have its first annual meeting on September 25, 2013, 10am-11:30am, at Carmichael's Steak House in Chicago, Illinois, just ahead of the Chicago Indie Spirits Expo to be held later that day in the Carmichael's Warehouse. You can learn more about the ICDA on Facebook: https://www.facebook...lersAssociation and the web site should be up and running shortly. Any TTB licensed distillery producing in Illinois is eligible to become a regular member, and those who join before the first annual meeting will be listed as founding members of the ICDA.

We purchase from both Black Swan and Barrel Mills, and have had good product from both. I don't know how their price compares to others, but comparable to each other. I suggest you contact them. All of the suppliers appear to be heavily subscribed, though.

For the most part I agree with this characterization, maybe with the following caveat: blending can be craft, just not craft distilling; rather, that might be called a craft blender, if you want to stretch it. And so on. But I suspect the ACDA should be concentrating on what a craft distiller is, and leave to others the other definitions for now?

I would consider more but smaller tubes.