Hang_Luce

Hi There! I'm prepping my first absinthe formula for submission, and came across the new Modernization rule published by the TTB, which says, in part::: "With regard to the laboratory testing requirement, TTB is removing the testing requirement for products made with wormwood, and will update published guidance to reflect this change. However, TTB intends to continue to offer the same type of thujone-testing that it has previously provided for the next year, and will assist industry members and outside laboratories to develop their own thujone-testing capabilities." I talked to a self described "TTB worker bee" on the phone yesterday, who was under the impression that they have stopped doing lab testing for thujone themselves, but are still requiring beverages be "thujone-free"--- and haven't yet published that guidance they allude to above. So basically, it seems like they are putting the onus on distillers to find a way to make sure absinthes are below the FDA-mandated minimum thujone amount... Does anyone have any experience with getting absinthe approved since this rule has passed? It makes me a little nervous, since beyond the fact we're a tiny operation and this sounds expensive, presumably they will now be enforcing this rule with product testing--- so even if/when we do figure out a way to test for this, there are enough variables in production (where the wormwood's coming from, time of year harvested etc etc) we could use identical production techniques and have one batch be below the level, and the next be above! So I guess I'm looking 1) to commiserate about how this rule might actually make things more complicated, and 2) for any tips on moving forward, either with finding a lab who can do this kind of thing, or a way to test ourselves, or a way to ensure our production technique minimizes thujone levels! Thanks, Nate

Hi folks, I've got a quick question about the new-(ish) bond regulations. It seems like my forthcoming nano-distillery will fall well under the $50,000 tax threshold for not needing a bond. Does anyone know how that affects all of the TTB application sections that refer to the "bonded premises"? Will I be asking for trouble if I just write "N/A" for all of those, given there won't be any "bonded premises"?

Hi folks, new to posting in the forum, though I've been lurking for quite a while... It's been so helpful so far, thank you! Anyway, I'm in the early/middle stages of starting a DSP focused on herbal spirits here in Maine, and have a few questions for folks as we really start to ramp up the pre-production work. Some pertinent info: We're going to predominantly be purchasing NGS to make amaro, aquavit, and uncategorizable / lesser known old-world-inspired stuff. (I know that makes us not actually a distillery, but I hope you'll still have us here.) We'll be operating on a tiny scale to begin, will have an attached tasting room, and are in a fairly well-trafficked tourist spot. Right now we've put together a business plan with a couple years of (speculative, conservative) financial projections, we're working out the details of the lease with a landlord, and have secured a loan from a local development bureau and a little additional $ from family/friends to cover payments until income starts coming in. First--- we are planning to eventually move on to doing secondary distillations : absinthe, gin, etc. Does anyone have thoughts about if it makes more sense to apply for the proper distillery license off the bat, even if we won't be distilling anything initially (and potentially for 2-3 years)? Or if we should apply for the 'blending' DSP license, and then alter/upgrade it when we're ready to distill? I imagine the latter option might help us get up and running a little bit more quickly, but that's just speculation. Second--- looking for a little clarity about the concept of "premises" in terms of our bond. I know that we can't be in the same building as a residence, and that we can't operate in the same premises as another business. Does that mean we can't be in the same building as another business, or just that we can't occupy the same space? We're hoping to be on the first floor of a Main St building that has a counseling practice on the second floor, with its own separate entrance and no passage back and forth. Is that kosher? Along the same lines, we're hoping to include the basement in our bond for storage/aging, but one must walk through the (non-bonded) tasting room and outside, on the sidewalk, to the back of the building to access the basement. It's a pain, I know, but will that pass muster legally? Lastly (for now)--- Can anyone point me towards either safety regs or sources for storage of high-proof spirits? I've heard informally that a certain grade of steel tank is necessary to transfer into once we receive a tote, but not sure if that is only above a certain volume of material/ sq footage of the space. Thanks so much in advance Hopefully this isn't re-hashing old info elsewhere on the forum.