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Jedd Haas

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Everything posted by Jedd Haas

  1. If withdrawn tax free, they should have been recorded as withdrawn for research and development, and the disposition to the "library." There is a section in 27 CFR that explains the data that needs to be recorded in the daily records for these samples. You don't have to pay taxes on library samples, but you do need to document the withdrawal. Once they're withdrawn, the are no longer part of your inventory. If the samples were withdrawn tax determined, then once again they are no longer part of your inventory. In that situation, I would suggest marking the bottles as "tax paid" along with the date of withdrawal and other supporting details as needed.
  2. It looks like they are another one of these unlicensed sites that sells through 3rd party local liquor stores. They list products and take a fee for placing the order. Some of them just add products without permission, apparently in the hope that distilleries will pay advertising fees to them. You can take them down with a DCMA request.
  3. Jedd Haas

    Color of Aged Rum

    For a 15 gallon used barrel, for rum, I like 2 years (or more).
  4. I have occasionally had the opposite problem. A barrel with a side bung that I want to store vertically. In some cases, I have made a "safety" to go over the side bung. A strip of stainless sheet held by some copper nails. Probably not necessary, but better safe than sorry.
  5. Bigger supply hose is better. That way you are much less likely to cavitate the pump and get irregular output.
  6. 1. Water treatment: Sediment filter, carbon filter, RO system. 2. Blending tanks: Food grade stainless tanks, plastic drums. 3. Hoses: Surplus pharmaceutical hoses. Silicone, teflon. Check a chemical compatibility database. 4. Pimps? Pumps! Air powered double diaphragm pumps. If buying used, check that previous use is not dangerous. 5. Labeling machine? Build your own. 6. Filling machine: Xpressfill. Several of these answers can vary depending on what you plan to blend and bottle; and the anticipated volume. Don't forget about cleaning, gauging, and any other requirements specific to your location. What is your location?
  7. Run the output hose into the top of a 55 gallon drum. Then it just steadily streams into the drum. Problem solved. You will have to mindful of turning it on and off at the right times. Or you can build an automatic shutoff system.
  8. 1. Talk to your insurance agent. 2. Talk to your local or state health department (or whatever agency regulates commercial kitchens). 3. Talk to your fire marshal, building permit office, and any other relevant agencies. 4. After receiving contradictory advice, rules, and requirements from all the players listed above, try and get them to talk to each other and agree! (Joke...or maybe not.)
  9. It's going to be a DSS. Any labels that have it approved as "whiskey" are likely older labels that got through before TTB got up to speed on distilling beer. Alternately, you could make a variation of your beer that conforms to the standards of identity for whiskey. You would have to use only grain, no adjuncts, and no hops during mashing and fermentation. After distillation, you could flavor it with hops and this would probably be approved as "hops flavored whiskey."
  10. @SlickFloss Can you explain what you did to remove the steel contamination? Electrolysis perhaps? Sadly, I dumped a barrel today with totally black spirit. It turned out that some jackelope had included a steel tool in the barrel before sending it to me. I had this happen once before and I redistilled it. But I would prefer to remove the contamination if possible.
  11. 1. Register as a "Primary Source." This registration must be renewed every year. Send copies of all permits by email. 2. Set up an account on Intax. (Not Intime.) 3. File a report every month on products shipped to Indiana on Intax. If there were no shipments during a given month, file a "zero report." Indiana is currently transitioning everything from their previous filing system, Intax, to a new one called Intime. There are all kinds of warnings on their site to hurry up and get on the new site. However, Alcohol PS filers have to keep using Intax for about one year more. This isn't explained on the site, but if you call them they will tell you.
  12. All American Containers. Contact Denise Sztroin, dsztroin@allamericancontainers.com
  13. In general, all spirits distilled from fruit are brandy. However, there is a specific rule for grape brandy: it must be aged for a minimum of two (2) years in oak to be called brandy. Any less than that and it will be immature brandy. Since your brandy is distilled from grapes, and is aged less than two years, it is immature brandy. Try again with that term as the class and type. In the case of Remy, they may have distilled it to neutrality. Additionally, if you look at the Production report, you'll also see that brandy has two options: either below 170° or above 170°.
  14. I contacted TTB and they said they would post further guidance on their site.
  15. Install an RTD with a remote display.
  16. @SlickFloss I would also be interested to see any documents you can share that back up the position you outline above. In the meantime, I contacted TTB and asked about this issue. Here is my message to TTB and their response. Message to TTB: Comments: re: CBMA Your guidance states: "The 2020 Act makes permanent the reduced tax rates previously enacted on a temporary basis, with a change to the definition of eligible processing effective in 2022." I reviewed section 5002(a)(5)(A) and it is essentially a circular definition. Can you provide a list of "eligible processing" activities? Also, please comment on which of the following activities qualify: 1. Changing Class & Type. For example processing Neutral Spirits into Vodka. 2. Mixing a flavored product. For example, adding flavors to whiskey to make a flavored whiskey. 3. Filtration. For example, filtering whiskey purchased from another distillery prior to bottling. 4. Blending spirits of different types together. For example, mixing Bourbon Whiskey with Rye Whiskey to create a blend of bourbon and rye. 5. "Finish" aging in a different barrel type. For example, aging whisky in a rum barrel. Please advise on which of the activities described above would qualify, and please also provide a list of other examples of qualifying processing activities. TTB Response: Thank you for your inquiry regarding the types of operations that are considered “processing” for purposes of the reduced tax rates for distilled spirits under 26 U.S.C. 5001(c). As reflected on TTB’s <https://www.ttb.gov/alcohol/craft-beverage-modernization-and-tax-reform-cbmtra> CBMA guidance page, changes to the type of processing activities that qualify for the reduced tax rates apply to distilled spirits removed after December 31, 2021. Under these changes, a distilled spirit shall not be treated as processed for purposes of the reduced tax rates unless a process described in 26 U.S.C. 5002(a)(5)(A) (other than bottling) is performed with respect to such distilled spirit. TTB will be issuing additional public guidance in the future regarding the types of operations that are treated as processing for this purpose. As additional information becomes available, it will be posted on the <http://www.ttb.gov/>TTB website. Bottom line: TTB has the remainder of the year to post clarification on eligible processing operations.
  17. In addition to fire officials, local building officials will have more to say. The answer to OP's question is highly dependent on location and the building codes and fire codes that are in effect. OP will have to deal with all of that before even trying to run it past TTB.
  18. Are you regulated by your state Health Department? Try contacting them. That would seem to be the most likely authority having jurisdiction. If they resist, perhaps you can make a case that they're guard cats.
  19. No experience with them, specifically. But it appears they are another marketing site that doesn't actually sell anything. Read the fine print: " All orders are fulfilled by Local Retailers"
  20. Dave has hit on exactly the point I was wondering about when I read that provision, which is section 109 of the legislation. There are a couple other apparent loophole-closing provisions in sections 108 and 110. I have attached the 25 pages of legislation, which I extracted from the full 5500+ pages of the final bill. See pages 22-25 of this file for sections 108-110. CBMTRA-2020.pdf
  21. 1. As part of your Daily Records, create a "destruction" form. 2. Record all details of the destroyed spirits on this form. It should include date, serial number, type of spirits, PG destroyed, perjury statement, etc. 3. Report it as destroyed on Line 19 of the Processing Report. Alternately, you could use Line 20 of the Storage Report, or perhaps report it as withdrawn for R&D on Line 12 of the Production Report. You would also want to have an additional R&D withdrawal form for this last option. 4. Keep all documentation on file.
  22. Try a hot PBW solution, let it soak for 30 minutes or more at 125° F. Then a hot water rinse. Repeat the PBW & hot water cycle if needed. Star San after all that if you want to sanitize it.
  23. Pete, What enzymes are you using and what temperature are you adding it at? I have tried a number of different high temperature enzymes. My favorite alpha amylase enzyme so far is Amylex 5T, which is (apparently) from a company in Denmark (Danisco) but made in China and it's all part of the DuPont conglomerate. I add it on the way up, temperature-wise, at around 130 or so. It's rated for around 190° F, so I suspect it denatures as I go to 200-210 and hold there. But the mash stays thin; and once I go back below 190, I add a bit more just to be sure of full liquefaction. For reference, you may recall this other thread which has some great information about enzyme protocols for rye.
  24. 1. Look for a label designer with examples of spirits labels in their portfolio. Make sure these are actual labels used in commerce, rather than concept pieces. You want to be sure your designer knows how to get your labels through the approval process, whatever that may be in the UK. If your designer has never designed a spirits label before, find another. 2. Pick out several labels for commonly available spirits that you like. Try to write up a description of what you like about these labels. The style, the colors, the typography, the paper stock. Likewise, find labels you don't like, and write up what you dislike about them. This is the beginning of your "design brief" - a written description of the design goals for your label. If you can produce a design brief, it will make the process of designing your labels much easier. Designers often have nightmare stories about working with "amateur" clients who don't know anything about design or the design process. The more you do to get yourself past the amateur stage, the better. 3. Find your printing company. Ask for samples of spirits labels they have printed. As with the designer, if they have no experience in this area, move on. Be very careful to ask if they actually printed the labels themselves. Many printing companies will take on all jobs that come in the door, but then outsource to a specialist printer. You wind up paying more in that scenario. So make sure they actually do what they say they do. Looking through their samples, ask about special processes, such as spot varnish, dome varnish, embossing, foil stamping, and die cutting. Ask about the range of papers they have available. Also ask them for names of designers. They may try to sell you on their in-house design, but this probably won't lead to the best results. 4. After you have reviewed portfolios from several designers, pick out the one that fits with your design goals. Are they excited about working on your labels? Ask for their price quote for the job. Typically, this should specify a certain number of "comps" or initial designs; a final design; and a certain (reasonable) number of revisions. Meaning, during the process, you must make a decision; if you vacillate, expect to be charged more. These scenarios should be spelled out in the design contract. 5. Make sure your contract specifies ownership of the files (or not). Some designers will charge more to "buy out" ownership of the files. The reasoning is that you are purchasing the end product. You might compare this to software, where you buy the finished program, but pay more for the source code.
  25. I tried to ship to Canada one time. Canadian customs stole the shipment.
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