Pour Decisions

I'm in the packaging supply industry and unless you are able to stumble across someone with excess, you likely wont be able to get any for quite some time. The production mills I work with are between 4 weeks to as high as 20 weeks out for these smaller containers. the shorter lead times are if you are purchasing by the trailer load.

I don't know what your volume or run sizes are, but the type of labeler you would need would likely cost more than it would to have quality labels produced for you. As bluestar pointed out, you'd need a coating applied to prevent them from being affected by the spirits. I can assist in sourcing labels for you as this is part of what i do for my day job.

@highwood28, my day job just purchased 400 cases of your hand sanitizer, I have some happy customers!

There needs to be physical separation (floor to ceiling wall or partition and not just a railing) between the bonded distillery production area and the (not part of your DSP premises) tasting room/serving area/sales area.

So a Dr will now be distilling his own alcohol, interesting... crazy times indeed

Sounds like a disaster in the making to me. That location has no provisions to do any type of processing so if used solely for barrel storage it would need to be zoned accordingly as a Hazardous location, and sprinklered appropriately. You'd then need a transporter permit and a processing permit when the barrels are aged. I'd post iup in the main forums to get some more input from those with much more knowledge and experience than me

They'll just label it as whatever they think it is and sell it., I get it, but that just pisses me off, way too much false advertising and inaccurate labeling out there. I am one that tends to read labels for almost everything I purchase and expect accurate information.

@John Bassett well, they are just idiots. What labeling will they use and what will it say the alcohol content is? Not expecting you to answer that BTW

@DrDistillation This is the same excerpt I posted in the other thread regarding sales. Of those 13 reasons listed, #1(c) covers it 26 U.S. Code § 5214 (a)Purposes Distilled spirits on which the internal revenue tax has not been paid or determined may, subject to such regulations as the Secretary shall prescribe, be withdrawn from the bonded premises of any distilled spirits plant in approved containers— (1)free of tax after denaturation of such spirits in the manner prescribed by law for— (A) exportation; (B) use in the manufacture of ether, chloroform, or other definite chemical substance where such distilled spirits are changed into some other chemical substance and do not appear in the finished product; or (C) any other use in the arts and industries (except for uses prohibited by section 5273(b) or (d)) and for fuel, light, and power; or

26 U.S. Code § 5214 (a)Purposes Distilled spirits on which the internal revenue tax has not been paid or determined may, subject to such regulations as the Secretary shall prescribe, be withdrawn from the bonded premises of any distilled spirits plant in approved containers— .... (11) free of tax when contained in an article (within the meaning of section 5002(a)(14)); Whereas "article" is defined as 26 U.S. Code § 5002(a)(14)Article Unless another meaning is distinctly expressed or manifestly intended, the term “article” means any substance in the manufacture of which denatured distilled spirits are used.

correct, PET just tends to be clearer

My day job is supplying packaging materials to manufacturers all over the place. I have access to a few suppliers that have availability of various sized containers and closures that will work. What sizes are you guys seaking? I assume an 8 oz clear PET with white or black sprayer and perhaps a 16 oz as well? Are most of you guys producing liquid or gel sanitizers?

26 U.S. Code § 5214 (a)Purposes Distilled spirits on which the internal revenue tax has not been paid or determined may, subject to such regulations as the Secretary shall prescribe, be withdrawn from the bonded premises of any distilled spirits plant in approved containers— (1)free of tax after denaturation of such spirits in the manner prescribed by law for— (A) exportation; (B) use in the manufacture of ether, chloroform, or other definite chemical substance where such distilled spirits are changed into some other chemical substance and do not appear in the finished product; or (C) any other use in the arts and industries (except for uses prohibited by section 5273(b) or (d)) and for fuel, light, and power; or (2) free of tax by, and for the use of, the United States or any governmental agency thereof, any State, any political subdivision of a State, or the District of Columbia, for nonbeverage purposes; or (3)free of tax for nonbeverage purposes and not for resale or use in the manufacture of any product for sale— (A) for the use of any educational organization described in section 170(b)(1)(A)(ii) which is exempt from income tax under section 501(a), or for the use of any scientific university or college of learning; (B) for any laboratory for use exclusively in scientific research; (C) for use at any hospital, blood bank, or sanitarium), (including use in making any analysis or test at such hospital, blood bank, or sanitarium), or at any pathological laboratory exclusively engaged in making analyses, or tests, for hospitals or sanitariums; or (D) for the use of any clinic operated for charity and not for profit (including use in the compounding of bona fide medicines for treatment outside of such clinics of patients thereof); or (4) without payment of tax for exportation, after making such application and entries, filing such bonds as are required by section 5175, and complying with such other requirements as may by regulations be prescribed; or (5) without payment of tax for use in wine production, as authorized by section 5373; or (6) without payment of tax for transfer to manufacturing bonded warehouses for manufacturing in such warehouses for export, as authorized by law; or (7) without payment of tax for use of certain vessels and aircraft, as authorized by law; or (8) without payment of tax for transfer to foreign-trade zones, as authorized by law; or (9) without payment of tax, for transfer (for the purpose of storage pending exportation) to any customs bonded warehouse from which distilled spirits may be exported, and distilled spirits transferred to a customs bonded warehouse under this paragraph shall be entered, stored, and accounted for under such regulations and bonds as the Secretary may prescribe; or (10) without payment of tax by a proprietor of bonded premises for use in research, development, or testing (other than consumer testing or other market analysis) of processes, systems, materials, or equipment, relating to distilled spirits or distilled spirits operations, under such limitations and conditions as to quantities, use, and accountability as the Secretary may by regulations require for the protection of the revenue; or (11) free of tax when contained in an article (within the meaning of section 5002(a)(14)); or (12) free of tax in the case of distilled spirits produced under section 5181; or (13) without payment of tax for use on bonded wine cellar premises in the production of wine or wine products which will be rendered unfit for beverage use and removed pursuant to section 5362(d). (b)Cross references (1) For provisions relating to denaturation, see sections 5241 and 5242. (2) For provisions requiring permit for users of distilled spirits withdrawn free of tax and for users of specially denatured distilled spirits, see section 5271. (3) For provisions relating to withdrawal of distilled spirits without payment of tax for use of certain vessels and aircraft, as authorized by law, see 19 U.S.C. 1309. (4) For provisions relating to withdrawal of distilled spirits without payment of tax for manufacture in manufacturing bonded warehouse, see 19 U.S.C. 1311. (5) For provisions relating to foreign-trade zones, see 19 U.S.C. 81c. (6) For provisions authorizing regulations for withdrawal of distilled spirits free of tax for use of the United States, see section 7510. (7) For provisions authorizing removal of distillates to bonded wine cellars for use in the production of distilling material, see section 5373(c). (8) For provisions relating to distilled spirits for use of foreign embassies, legations, etc., see section 5066.

They are not technically selling, but requesting donations

I may have some available, I will report back asap!

"Alcohol, whether or not denatured, may be delivered tax-free to state and local governments for non-beverage purposes. The same is true for hospitals, blood banks, sanitariums, certain pathological laboratories, non-profit clinics, and qualifying educational institutions, if not for resale or use in the manufacture of any product for sale." and "In addition, any existing DSP may remove undenatured or denatured ethanol from bonded premises free of tax for use by hospitals, blood banks, sanitariums, certain pathological laboratories, non-profit clinics, and qualifying educational institutions seeking to use it to manufacture hand sanitizer, and not for resale or use in the manufacture of any product for sale." These statement refer to tax free ethanol, no where does it state that you cannot remove tax accrued or tax paid alcohol for the production of hand sanitizer for sale.

no help in your search, but just chiming in to welcome another new PA member!

You plan to source bottled product, warehouse it and sell it where? If this is the case, you would need an Alcohol Wholesale/importer permit

Your local zoning folks will tell you. They are usually pretty helpful. Here's a copy of your zoning ordinance https://www.sandiegocounty.gov/content/sdc/pds/zoning.html

Older thread, but relevant with the new Notice 176 revision being published tomorrow. New terminology is "TTB is finalizing the expanded alcohol content tolerance as proposed, to plus or minus 0.3 percentage points." Full information in the attached 2020-05939.pdf

'Macon Spirits' shine, sorry had to sing that one in the Jingle Bells fashion

I read that article and watched a bit of the actual press conference. Curious as to when the state determine hand sanitizer would be an important item to produce on their own (well, for them really)?

I've been lurking and learning. thank you all for this post. As confusing as some of this stuff already is, this current state of the union makes it even more so! Wish I had something to add other than hopefully by the time this bug comes back around, there will be some more concise guidelines in place, oh, and I have my DSP!

mwahahaha

Thank Foreshot, I have not spoken to them yet. I did some measuring with my contractor and decided to just ahead and make it ADA compliant.