Jump to content

JNorris

Members
  • Posts

    48
  • Joined

  • Last visited

  • Days Won

    4

JNorris last won the day on August 27 2022

JNorris had the most liked content!

Recent Profile Visitors

1,623 profile views

JNorris's Achievements

Active Contributor

Active Contributor (3/3)

7

Reputation

  1. Have you looked at K-RAX: https://www.kraxbarrelstorage.com/
  2. I will advise this again, be sure to use a customs broker that understands bulk spirits and the fact that you, as an importer of bulk spirits, do NOT pay excise tax on those bulk spirits at port, only customs and duty. Get this in writing from them. I have a few horror stories about this, and it was not good times. 1. You apply for an importer's permit on permits online 2. Yes, a good one that deals in bulk spirits preferably. 3. Yes on the Fed side, you need to research your particular state. There are 4 different Federal Storage reports: Domestic, Imported, Puerto Rican, and Virgin Island. You will submit your Domestic report and whichever Imported report matches the spirits you are bringing in.
  3. Hi! I am Jennifer Norris. You might remember me from companies such as Whiskey Systems and Doc Collier Distillery. I am now running my own compliance consulting business for distilleries. I have over 20 years of experience in the wine & spirits industry with 10 of those years dedicated to distillery compliance. Dave Dunbar @dhdunbar has been a mentor to me over the years and more so since his recent retirement. He has been referring his clients to me and assisting me with some of your more interesting queries. Thank you to all who have come my way via Dave Dunbar, and many thanks to Dave for sharing his knowledge with me and also sharing it with all of you on this forum! He is a legend here. I hope to be on this forum more often answering your questions; I am not sure I can fill Dave Dunbar's shoes, but I will try. I have had the pleasure of working with many of you before and hopefully I will meet some more of you via this forum. I hope that you will reach out if you need permit assistance, internal audit assistance, TTB audit assistance, report and return clean-up, compliance training, COLAs, formulas, or if you want me to ask questions to the TTB for you so you can stay anonymous. I also teach my clients how the operational reports work and I assist them with their monthly reports as needed. I will be at ADI in Las Vegas; I will probably be the only young-ish gray, curly-haired female there, so please introduce yourself when you see me! I am here when you need me and I look forward to catching up with y'all, meeting some new people, and helping y'all stay compliant! Jennifer Norris
  4. The regs state that they must be tested "at representative intervals." What does an interval mean to your business? I tested at the beginning, middle and end (although we only bottled less than 40 cases every time). The beginning to make sure all the fillers and the proof are within tolerance. In the middle so that you can make any necessary adjustments if needed. And at the end so that you can confirm that you have been within tolerance during the duration of your bottling. I would suggest doing more testing in the middle of you are doing larger bottlings. Really, write up a bottling fill and proof check SOP and stick to it.
  5. @Minhwa Spirits The first place I would start with would be the state ABC and/or the DoR, or whoever handles the state excise/sales taxes. They should have the information about the rules you need to play by and the taxes you must pay. And the information is free, although it can sometimes be very hard to find someone who can answer your questions. If you do find answers, be sure to ask them to send you an email with the information so you can keep it for reference and keep their contact information, because a good/knowledgeable contact is very hard to find.
  6. @Obtainium Getting the import permit from the TTB is the only federal license you need besides your DSP basic permit to process those bulk spirits. Once you have those, be sure to get with a good customs broker. YOU DO NOT PAY EXCISE TAX AT THE PORT FOR BULK SPIRITS. Make sure your broker understands this and get it in writing. I have seen a number of producers who import and the brokers force them to pay excise at port. Well, now you have tax-paid bulk spirits that cannot be on bonded premises and you have a good fight with the broker to get your money back.
  7. § 5.47a Metric standards of fill (distilled spirits bottled after December 31, 1979). (a) Authorized standards of fill. The standards of fill for distilled spirits are the following: (1) For containers other than cans described in paragraph (a)(2), of this section - 1.8 liter 1.75 liters 1.00 liter 900 milliliters 750 milliliters 720 milliliters. 700 milliliters. 500 milliliters (Authorized for bottling until June 30, 1989) 375 milliliters 200 milliliters 100 milliliters 50 milliliters (2) For metal containers which have the general shape and design of a can, which have a closure which is an integral part of the container, and which cannot be readily reclosed after opening - 355 milliliters 200 milliliters 100 milliliters 50 milliliters
  8. It is not unusual for a new distillery to take twice as long to get going and with three times the amount of money originally thought, or I heard it all the time from my customers. There are so many details that new entrants do not consider before jumping in headfirst. Compliance is a huge one. As noted above, the snap can make your life easier for quick gauges of only alcohol and water, but cannot be used for final proofing or for obscured spirits(anything other than alcohol and water). Many do not know this. You still need to have certified hydrometers and thermometers for all of your final proofing, and really you should have 2 of each hydrometer because, trust me, they break. For obscured spirits, you need a lab still as well. I have helped a number of new distilleries with their compliance and all the little things that you should know that turn into big things like reports, records, proofing, etc. If anyone needs any help, guidance, has compliance questions, etc just send me an PM here.
  9. I have not used CRU or CDA-USA, but I did have a Xpressfill 4 spout volumetric filler that I was very pleased with. It was affordable and worked! It replaced an enolmaster 4 spout that constantly had issues. I had 1 issue with the xpressfill and the company rushed a part out to correct the issue, so the customer service was great.
  10. The answer from the TTB today was, we are actively working on further defining the addition of water and its effects on the rates. The 2 examples of adding water that I was given is someone proofing 190 down to 80 for bottling, or someone who proofed 190 to 81 then TIB'd it out for a bottler to add a little bit of water to get it to 80 before bottling. I take it they see a distinction between these two and the tax rates associated with the addition of water, BUT we shall see. The end result is that more information is coming...
  11. I went back through my notes, and on 2 separate occasions the same TTB higher up has said "we have stated that even adding water will count ... as to being a processor." If the new guidance now does not include adding water to ensure label proof as a "processing" operation, I wonder what changed their minds in between then and now. I hope my interpretation of this guidance is incorrect. I believe a call to the TTB for clarification is on my to do list today. Of course, if you ask 3 different people there the same question you will, more than likely, get 3 different answers.
  12. The "processing" changes go into effect January 2022. If it is correct that proofing is not considered processing, and that is how I took it, I wonder how many people are going to be tax paying a large number of cases to get the reduced tax rate this year. (If you do this be sure to keep your cases in a tax-paid area.) For next year, if filtering is the minimum for processing, filter your spirits. It does not specify what kind of filter, only "otherwise physically changes the distilled spirits inside the container, including filtering distilled spirits to remove material from those distilled spirits." If you have to justify the money, and you will, be sure to keep records of your filtering operations for audit purposes.
  13. I know of some distilleries that are reusing their sample bottles as more sample bottles only, but none that are accepting bottles back from customers that I know of.
  14. Handwriting on labels is something I warn some of my new customers about. It is easy when you are starting out but becomes a nightmare as you grow: keeping track of numbers, writing on every label, and writing legibly. My suggestion is to get with your label company; they have many different fonts and many of them look like handwriting. Ask for font samples and settle on one that you like. If it were me, I would drop the bottle numbers, as preprinted labels will undoubtedly not end up being sequential once they get on bottles. For example having to burn through 15 labels just to get your labeler to work correctly today. Maybe that is just an OCD thing though.
  15. For anyone who wants to learn how to proof your own spirits using a lab still IM me, and I can teach you. You can spend $250- $500 on a lab still and learn how to do it yourself or pay a lab to do it for you every time. Labs are charging....$90-$120 for a proofing test, ONE proofing test. (Dang, I remember when this was $30!!! ...it looks like I am in the wrong business, maybe I should start a lab for testing/proofing spirits.) Oh and you have to pay shipping. AND you have to proof your spirits before you bottle, so a sample from every batch would need to be sent to a lab for proof testing before you could bottle. You can see how the costs will add up quickly.
×
×
  • Create New...