Jedd Haas

I haven't done this yet but have thought about different methods. One idea is to structure it as an "exclusive right to purchase" the finished bottles. The customer can then pay you a deposit. For example, 99% of the final price. That way the barrel is still technically yours and no reporting would be needed. They can then pay the final amount when the barrel is dumped, bottled, and the bottles are withdrawn. However, are you allowed to sell an entire barrel's worth of bottles to your customer all at once? This will vary by state, but this problem will only arise when the spirits are withdrawn.

What brand and model of lab bath with chilling did you purchase?

This is a question where there are far too many unknowns to make any estimation of a dollar amount. Only you can determine what's fair. With that said, you might consider a licensing agreement, where the customer pays you based on every bottle produced. You might also make the license non-exclusive, so you can use it yourself or sell it to others. Or ask them what they think is fair; and ask them to explain how they arrived at their conclusion. It's probably best to engage in a discussion with them to reach a reasonable conclusion. But one more thing: based on the minimal information provided, I'm not so sure that "cherry pie flavored vodka" is all that difficult. There are multiple companies in the flavor business that will sell all kinds of flavors. There are likely several companies that have "cherry pie" flavors readily available. So you might look into that aspect as well, and try to determine if you can really create something that's far superior to "off the shelf" offerings.

Possibly. You want to look up "non contiguous extension of DSP premises." You'll find this as one of the options in Permits Online. Anecdotes suggest that if the locations are within 10 miles of each other, it may be approved. But that rule isn't written anywhere.

There is another thread from a while back which mentions the several types of electric forklifts that are suitable for distilleries. I contacted a local vendor and was quoted $17k for a used forklift that was compliant. Crown SC series, with charger.

It seems the TTB has taken a big step backward in usability. Now you have to enter the data, and then render the PDF. Data from the previous month also wasn't carried over, which led to a few glitches as I figured out the new system. I have a hypothesis as to the reason for the change. Many years ago, I needed some previously filed forms that were lost (long story). TTB was able to retrieve them, but instead of getting the actual forms, I received a tabular layout of the data similar to the new data entry scheme that was implemented on pay.gov. So it appears that it was changed to make it more convenient for TTB and less convenient for us. Entering the data directly on the form was much easier. On top of that, there are some other annoying new "features." 1. Decimal points don't line up in the columns. They didn't line up correctly on the previous forms, but it seems worse now. 2. Totals are rounded to one decimal place (tenth of a proof gallon). This could potentially lead to errors down the line. Perhaps this means that TTB thinks that one decimal place of accuracy is close enough. One decimal place rounding is on the Storage form, but not the Processing form, which retains 2 decimal place calculation.

The answer to both questions is yes. https://www.ttb.gov/ponl-help/distilled-spirits-plant-application-preview

There was some previous discussion about what constituted "processing" when a DSP bottled spirits produced at another DSP. In particular, it was questionable as to whether simply proofing down the spirits was "processing" or not, relative to qualifying for reduced excise tax rates. TTB has issued some updated guidance and the answer is a clear NO. However, if the spirits are filtered, that does count as processing. Here is the full text of the guidance, see the section in bold below. NEW TR-D12: What domestic activities constitute “processing” for the purpose of determining eligibility for the reduced distilled spirits tax rates provided in 26 U.S.C. 5001? Reduced tax rates are allowed on distilled spirits that are distilled or processed by a DSP and removed by a DSP during the calendar year. A DSP is considered a processor of distilled spirits if it “manufactures, mixes, or otherwise processes distilled spirits” or “manufactures any article.” See 26 U.S.C. 5002(a)(5)(A). “The term ‘processor’ includes (but is not limited to) a rectifier, bottler, or denaturer.” See 26 U.S.C. 5002(a)(5)(B). For distilled spirits removed after December 31, 2021, “[a] distilled spirit shall not be treated as processed [for reduced rate purposes] unless a process described in [26 U.S.C. 5002(a)(5)(A)] (other than bottling) is performed with respect to such distilled spirit.” See 26 U.S.C. 5001(c)(5). For purposes of the reduced rates, a DSP is considered a processor of distilled spirits if it: manufactures distilled spirits, mixes distilled spirits with materials including flavors, wines, water (except that the addition of water during the normal process of bottling for the purpose of ensuring label proof does not constitute “processing” for reduced rate purposes), or other distilled spirits of any type, and/or otherwise physically changes the distilled spirits inside the container, including filtering distilled spirits to remove material from those distilled spirits. Processing does not include changing the marks or labels on distilled spirits containers or repacking containers of distilled spirits without physically changing the distilled spirits inside the containers. Note: Eligibility for the reduced tax rates or new tax credits may be limited by application of the single taxpayer or controlled group rules. Originally issued on 12/14/2021 Updated on 12/14/2021* Source: https://www.ttb.gov/alcohol/craft-beverage-modernization-and-tax-reform-cbmtra#TR-D12 There are also two other new guidance sections on transfers in bond: https://www.ttb.gov/alcohol/craft-beverage-modernization-and-tax-reform-cbmtra#TR-D10 and https://www.ttb.gov/alcohol/craft-beverage-modernization-and-tax-reform-cbmtra#TR-D11

Try contacting a sugar refinery.

I also recommend Norit for bulk carbon. For the big blue cartridge filters, if you mean the ones that are 4.5 x 20, I have been buying them on Amazon.

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.

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.

For a 15 gallon used barrel, for rum, I like 2 years (or more).

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.

Bigger supply hose is better. That way you are much less likely to cavitate the pump and get irregular output.

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?

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.

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.)

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."

@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.

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.

All American Containers. Contact Denise Sztroin, dsztroin@allamericancontainers.com

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°.

I contacted TTB and they said they would post further guidance on their site.

Install an RTD with a remote display.