Jedd Haas

@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.

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.

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.

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"

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

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.

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.

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.

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.

I tried to ship to Canada one time. Canadian customs stole the shipment.

Xpressfill. Good functionality and very good support from the company. Be sure to get the high proof upgrade. It's not perfect, but it's good enough.

You came to the right place. What part of Louisiana are you in?

Has anyone tried actual samples of spirits that have gone through any of the "fast aging" systems? I spoke with a different company recently and requested samples of both "before" and "after" versions. We'll see if they come through.

How long was the product in 15g? What was the char level?

I thought you handled that loudmouth rather well, nice work, Pete.

There are several previous threads that discuss "gas pump" style filling valves.

1. Auto body slide hammer kit for around $20 on ebay. https://www.ebay.com/sch/i.html?_from=R40&_trksid=m570.l1313&_nkw=3+lb+auto+slide+hammer+kit&_sacat=0&LH_TitleDesc=0&_sop=15&_odkw=auto+slide+hammer 2. Special tool by Storz, $280. https://www.stortz.com/product/bung-puller/ Option 1 has worked well for me.

Air powered diaphragm pump, 3/4" or larger.

The original post by 3-Oaks is not completely clear, but I read it as wanting a method for determining how much liquid is in a particular 53 gallon barrel, presumably after some spirit has been lost to the angel's share. If that is indeed the question, here are two methods. 1. Make sure you record the tare weight before filling the barrel. After filling, record the weight. From time to time, weigh the barrel. Subtract the tare weight and convert weight to volume (with AlcoDens). You can also pull a sample and check the proof to increase precision, rather than using the entry proof. 2. when you get a new barrel, fill it with water, one gallon at a time. After each gallon, insert a dowel. Mark the dowel at the high water mark. Assuming your barrels are all from same supplier and are relatively consistent, this will give a you gauging stick to measure the amount in a barrel. In both cases, some liquid will be absorbed into the wood and will not be recovered. If you keep good records, you'll eventually determine the subtraction amount for this loss as well.

1. Report on the Production report as Alcohol and Spirits, or Rum, (depending on distillation proof and your preference). 2. Use line 9 on the Production report to enter in Processing. 3. Receive in Processing (line 2). 4. Report the amount bottled on lines 9 and 28. 5. I would then use one of the blank lines (41, 42, 43) for the withdrawal and write in "hand sanitizer."

This one. https://www.thermoworks.com/Reference-Thermometer

Pete, I would like to see pictures of your big stripping still. How many plates does it have?

@meerkat That is exactly the information I was looking for. Thank you. The FDA guidance also states that a 5% ABV tolerance is acceptable, so 4.2 proof would be 2.1% ABV and well within the acceptable tolerance. @SCLabGuy quotes above the section of the FDA guidance I was referring to in the initial post. I will be using Bitrex for denaturing, so the change to apparent proof caused by isopropanol will not be a concern for me.

FDA states that the alcohol content should be verified and that a hydrometer reading is one of the acceptable methods. In the WHO guide, they show a hydrometer apparently reading 80% ABV, then state further that for "an isopropanol solution, a 75% solution will show 77% (± 1%) on the scale at 25°C." The WHO guide does not state a temperature for the (apparent) 80% ABV reading. For the ethanol formula, do the additional ingredients, particularly the glycerine, affect the hydrometer reading? If so, how much of an offset is there? Or should the hydrometer simply be read as-is and temperature-corrected to 60F per normal procedure?

AlcoDens. https://www.katmarsoftware.com/alcodens.htm