FIVE x 5 Consulting

Nothing's officially changed yet. I expect a final rule in 2024 but there's no guarantee. Till then, old "Malt Whiskey" requirements would generally apply: Whisky produced at not exceeding 80% alcohol by volume (160 proof) from a fermented mash of not less than 51 percent malted barley and stored at not more than 62.5% alcohol by volume (125 proof) in charred new oak containers

Hard problem! St. Augustine down in FL has one solution, pretty clever. Looks like a pretty standard beer tap (not even a Perlick). It's not actually coming from a barrel, but it looks like it is... If you want help with the regulatory compliance side of this plan, drop me a line. I've helped a few distilleries execute "fill your own" experiences (there are some major gotchas you may not have considered).

Hi! We make Whiskey Systems so I thought I'd pop in and give you some answers. 1. Yes, some folks indeed use external inventory tracking, but I would call it a small percentage. 2. QBO integration does not cause your Whiskey Systems inventory to appear in QB. Instead, it causes your financial transactions (dollars, not units) to appear in QB. QB integration likely wont help you get better inventory insight. 3. "Managing inventory" is a little broad and everyone's got different needs. To help you out here, I'd love to hop on a quick (no charge) call to discuss your specific needs. I'll PM you a link to book that consult in case you'd like to!

Interesting question. There's a free monograph for USP ethanol from the Bad Old Hand Sani days: https://www.usp.org/sites/default/files/usp/document/health-quality-safety/usp-hand-sanitizer-ingredients.pdf However, US Distilleries do not need to follow this monograph unless they want to label their neutral spirit as USP. I don't know that there's a hard limit specified for acetaldehyde. You have an obligation to avoid "adulterating" your products from FDA regulations. At what point would acetaldehyde cause a product to be considered (by FDA) to be adulterated? I don't know. Here's a survey of acetaldehyde levels from a 1983 study: https://www.ncbi.nlm.nih.gov/books/NBK531662/table/p5-T33/?report=objectonly Acetaldehyde is present in most fermented products and will carry over when distilling. Small producers typically don't even have the means to test for it. I'm not sure how TTB or FDA would go about regulating & enforcing such a limit. As for mandated levels of ethanol, the minimum is 0.5% ABV (1 proof degree). Below that point, it is not considered or regulated as an alcoholic beverage.

"NDP" or "Non-Distilling Producer" is another common name for these operations.

Sorry for the delay in responding! The NABCA spec wants the bottle GTIN in the bottom left. An SCC code (case code) would not fit the NABCA spec, which is what this label is intended to match. If you also need an SCC, that's a requirement beyond NABCA standards. You can meet that spec through the "Print State Label" function in Whiskey Systems, which has both bottle GTIN and case SCC codes on it: See NABCA spec here: Just curious, who or what state is asking you to use SCC instead of UPC on the 6x4 checkerboard control state label?

You could use it as a base for most any kind of "distilled spirits specialty" product. Think cocktails/RTDs, seltzers, liqueurs, amaro, aquavit, bitters. You can also use it as a base for Distilled Gin (but not Compound Gin, which requires neutral > 190). Finally you can bottle it as-is and it'll fall under Distilled Spirits Specialty with a Statement of Composition - something like "Spirits Distilled from Sweet Potato".

I'm with Silk City. Setting aside the fact that it's a normal production process all over the world, here in the US it is technically not Rum if you have fermentables other than cane products - doesn't matter the quantity. If fruit and/or sugar derived from fruit makes it into your ferment, you're in distilled spirits specialty territory. Yeast, enzymes and treatments like oyster shells are not fermentables and are not material to this analysis. I'd sure hate to put a ton of effort into a product like this only to find out later that you cannot call it Rum on your label!

It's certainly possible for proof to increase over time in a barrel as it ages. However, the scenario you have posited (where proof gallons increase over time) is not possible. Where did the 5 PGs of additional ethanol molecules come from? The air? The wood? You can only lose proof gallons over time, not gain. PGs are a separate measure from the proof of the spirits.

There is a fully-NABCA-compliant 6x4 option in Whiskey Systems under "Print CSC Label" - it was added in the last year or two. Give it a try?

Hi there, If you're using DISTILL x 5 or Whiskey Systems distillery management software, it can generate these labels for you automatically. WS: https://whiskeysystems.zendesk.com/hc/en-us/articles/10167742008343-Print-Control-State-Case-Labels Dx5: https://support.distillerysolutions.com/hc/en-us/articles/115004225805-Inventory-Setup-Print-Control-State-Labels-Read-Time-2-mins

TTB asked for letters on that very topic last year, and not a lot of folks responded. https://www.regulations.gov/document/TTB-2023-0005-0001

I got nothin', then. Very curious to hear how this shakes out, hope you'll keep us updated!

That's a noodle-scratcher! The first thing that comes to mind is your gauging methodology. Are you measuring your outputs volume by weight or by sight glass? Hydrometer/thermometer method for reading proof, or something else? If you have multiple operators and temperature swings, the chances of this varying increase. I had a client recently tell me about a discovery they made. Starting gravities were substantially lower than expected for some cooks. Looked like some wacky process thing that they needed to investigate. Turned out it was a new operator that was leaving rinse water in sampling vessels and diluting the wash pre-measurement. All was well, it was just a measurement error.

There's a quote from TTB's website stating: But there is no specific regulation I'm aware of that actually requires you to use Storage or Processing in any particular scenario. The advice I will give here is therefore based not on regulation but on my personal opinion, informed by my experience. I would show all of your white dog production on the Production report. The PGs that went into the two 15 gallon barrels would be deposited into cooperage in Storage. The remaining PGs would be Dumped into Processing Bulk (Pt I), without going through Storage first. The quantity that you bottled would move to Processing Pt II while the quantity in stainless awaiting bottles would remain in Processing Pt I until you bottle it.