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Bier Distillery

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    FDA Facility Fees

    in Hand Sanitizer Production

    Posted

    "on the heels of Association discussions with HHS Chief of Staff Brian Harrison and senior HHS leadership, together with an intensive outreach campaign over the past 48 hours to congressional legislators and members of the media, HHS has withdrawn the FDA’s scheduled $14,060 fees to craft distillers who produced hand sanitizer in 2020. "

    Still need to de-register for 2021 though. 4.5 hours left.

    FDA Facility Fees

    in Hand Sanitizer Production

    Posted

    16 minutes ago, bluestar said:

    Note some have already de-registered before closing market activity of the products. Once you have deregistered, ironically, you can't close the market activity of the products. It is unclear if you have to re-register to close the market activity of the products to avoid the tax liability, or if that will even work.

    So let's say theoretically a company with product on retail shelves goes out of business.  When/If they deregister, would everyone carrying their product no longer be able to sell them?  It seems to me there is a reason to still keep the products active, but the facility inactive/deregistered.

    FDA Facility Fees

    in Hand Sanitizer Production

    Posted

    This is as clear as mud, but it looks like you're probably right.  Anyone that registered with the FDA during 2020 is going to get screwed out of $14k even if you deregister now.  It doesn't make any sense whatsoever, so maybe someone knows more.

    https://www.federalregister.gov/documents/2020/12/29/2020-28714/fee-rates-under-the-over-the-counter-monograph-drug-user-fee-program-for-fiscal-year-2021?fbclid=IwAR1R41wSMRz8eFoDphxHoCHcK7kwyC2fQLCcO_SG9j1MvUAR5go9mAxKCKY

    "Under the statute, a facility fee will not be assessed if the identified OTC monograph drug facility: (1) Has ceased all activities related to OTC monograph drugs prior to December 31 of the year immediately preceding the applicable fiscal year; and (2) has updated its eDRLS registration to reflect that change (see section 744M(a)(1)(B)(i) of the FD&C Act). As the applicable fiscal year for fee-setting under this notice is FY 2021, the year immediately preceding the applicable fiscal year is FY 2020. December of FY 2020 is December 2019. Thus, a FY 2021 facility fee will not be assessed with respect to an OTC monograph drug facility that, prior to December 31, 2019, had ceased all activities related to OTC monograph drugs and updated its eDRLS registration to that effect."

    CIP in an IBC tote

    in Equipment

    Posted

    Assuming you're talking about a standard plastic IBC tote, the caps often have a 2" NPT thread on them.  Get one of those and a 2" NPT to 2" triclamp adapter and you're done.  

    If you're heating while cleaning, you're going to need some sort of pressure & vacuum relief or your IBC will become a big balloon.  You can also try putting the above cap on loosely enough where it doesn't really seal.

    Low efficiency

    in Technique

    Posted

    3 hours ago, Brewstilla said:

    So mashed two batches of bourbon today, each 350# corn, 110# unmalted wheat, 82.5# peated malt. Same mash regime as the original post, but the first one at 30 min rest at 195, and the second at two hour rest at 195, both 15 plato original gravity. Hammer milled all grain to flour, no clumping or any issues, ran perfectly smooth. Thoughts?  

    The final gravity is where it's at.

    Big Orders for Foreign Shipment

    in Hand Sanitizer Production

    Posted

    13 minutes ago, FijiSpirits said:

    I’ve had to buy a lot of equipment from USA as well as China and India. Usually it’s pretty easy working with everyone except USA or Australia. Both are quite xenophobic with regards to shipping overseas. 
     

    as an American I certainly understand there are plenty of scams around but perhaps I can offer some perspective for potential sellers. 
     

    payments:

    -in many nondeveloped countries It can be very very difficult to get a credit or even debit card that works internationally.  When we can they often require us to deposit the amount of the credit line in said bank, then get approvals from not only the tax agency but the bank for each transaction.  Further, these transactions also come with percentage fees. Further still exchange rates that are 5% or more below international market rates are common. 
     

    to complicate matters further some countries don’t have zip codes meaning that many vendors can’t or won’t process the card anyway.   I specifically remember dealing with Home Depot for three weeks trying to get them to process payment on a large order.  They couldn’t do a card or even a wire transfer for us. 
     

    - wire transfers or TT are the norm internationally. The seller will typically provide wire details and the buyer will send money. Of course there is a great deal of trust on the buyers pet and they really have no recourse should the seller crap out. 
       CONVERSELY the seller giving out wire details incurs almost no risk these days. With two factor authentication and security measures it’s almost impossible to get money out of that account. as a scammer (without the seller giving it willingly).  I ran in to this quite a bit, where mom and pop sellers were super paranoid of even taking my direct overseas calls much less making a sale or giving wire instructions.  For them , all overseas transactions were a scam. 
     

    - most overseas payments will require the buyer or wirer to show the bank or tax agency an invoice with payment instructions. This is copied and stamped and kept on file to ensure proper taxes are paid in their country. IT IS NECESSARY TO PROVIDE THIS to your customer so they can pay.   If you are asked to fudge the Numbers a bit on the SHIPPING documents it normally can help reduce taxation on the buyers side.  Never do this before you have received the proper payment on a proper invoice.  Shipping invoices are commonly different than payment invoices. It becomes the issue of the buyer to reconcile that with their tax authorities.  Really up to you if you will help them this way tho. It’s ok to say no. 
     

    shipping:

     Normally when I buy in china I will ask them to either give me a freight quote to the main port in Fiji. This is super normal for them and super easy for me.  They get it to Fiji then my guy here handles the rest and delivers to me. Easy. 
     

        In the USA I typically will place orders and have it sent to a freight forwarder whom I deal with directly from here in Fiji.  This makes it easy for mom and pop to ship nationally without the fear or hassle of filling customs documents. 
     

    in Australia when I order, if it’s not a well versed company in international orders I will just go to New Zealand. They are just much easier to deal with in general. 
     

    my suggestions to USA sellers to overseas clients:

     

    listen to them and get a feel for who you are talking To.  Many times accents or language barriers are a problem but give them a chance.   They have money and understand that USA cost more than China and are willing to pay for it. Let them. 
     

    apply a filter. If they call, ask for a follow up email or vice versa.  With China I find that if a company  is responsive with my emails and quick to provide quotes that they are usually very good with shipping, questions afterwards.  If it takes days to answer an inquiry and a week to provide a quote then shipping will be slow and after sale service will be poor.  Your buyer is judging you on this as well. 
     

    offer to accept a wire transfer or card payment but wait until it FULLY clears to ship. 

     

    Offer to ship to a USA based freight forwarder at their expense. 
     

    It’s really helpful to the buyer if you can quote shipment to a port in their country. I Don’t do “door to door” quotes. They are usually overpriced and can be a hassle if you arrange it.   Shipping to a place like Fiji is relatively easy your freight guy comes and picks up the order then gets it to the docks. Then it arrive here and I take over with my guy. My freight agent gets all the details and makes it all happen. He can also work with your agent directly easily. It’s what they do. 
     

    things I would not do:

    don’t pay for anything or become responsible for anything that has not been covered in full by their payment to you. 
     

    dont screw over a buyer.  If they pay you then do what you said. If you can’t then refund their money honorably 

     

    and don’t be afraid to answer the phone or email. Set conditions like I mention above. If they agree then fine. If there is something weird or payment this not forthcoming then bail early.  Set a price, provide an invoice and wiring instructions then let it happen. 

    Good points.  But, I don't think this is xenophobia (at least I hope not).  It's more like multiple red flags flying all at once.  "I'm from company so and so from where and where" and I google it and it doesn't exist (at least according to Google).  "Please use my trusted shipper from Somewhere, USA" with a random Gmail email address and I google that, and the shipping company doesn't exist as far as I can tell.  It's, "what credit cards do you accept", not will you take cash, ACH, EFT, Wire, etc.

    The first couple times I gave the benefit of a doubt and it crashed when I wanted them to arrange things with their own "trusted" shipper.  And then when I got identical initial/exploratory emails from the same "person" a couple months later... I'm like, don't you remember our conversation.  No, this is a scam, I'm not sure how it works, but it stinks.

    Big Orders for Foreign Shipment

    in Hand Sanitizer Production

    Posted

    I've been getting a lot of these since early May.  Usually they lose interest once I tell them they have to figure out their own freight (since they seem to be from companies I can't verify exist and they want me to use shipping companies that don't seem to exist).  I've started ignoring them.  It has to be some sort of scam, not sure how, but like you said, seems suspicious and not worth my time.

    • Thumbs up 1

    IAre you staying in the hand sanitizer business long-term?

    in Hand Sanitizer Production

    Posted

    I could very well be wrong, but to me it looks like Registrar doesn't do anything that you couldn't otherwise easily do yourself.  Registering your facility and product (even one that doesn't match the WHO/FDA guidelines like a gel) is relatively simple (and free) once you understand some basics.

    What I'm really wondering is what the process was for selling hand sanitizer before COVID.  It looks to me that any company could have registered with the FDA before COVID and started selling.  That seems incorrect to me but how?  Is this regulated by the states somehow?  Are there additional licenses to be had?  Google is failing me because all the references to hand sanitizer now are post COVID. 

    I've seen several mom & pop businesses pop up in the past few months selling sanitizers with their own proprietary recipe.  Are they doing so illegally?  Did they do anything other than registering with the FDA like we've all done?

    So on a related note, what must a distillery (and any other type of company) do to continue to sell sanitizer after Dec 30, 2020?  It's unclear to me.

     

    Bottle Rinser

    in Equipment

    Posted

    I think if you're concerned about your bottles contaminating your spirit, I'd find a different source of bottles.

    Mainly I'm concerned about removing dust and cardboard particles.

    • Thumbs up 1

    Bottle Rinser

    in Equipment

    Posted

    On 6/23/2020 at 1:11 PM, MichaelAtTCW said:

    For those who'd rather outsource tool building so they can focus on their product, we make a ready-to-use automatic recirculating rinser that's in tons of distilleries: The MiniMax.

    We just finished work on a four head version, by popular demand. The top and bottom sets of heads operate completely independently—they each rinse on their own timed cycles. This allows the user to get a good rinsing rhythm going for bottling. Two bottles rinse while the others are being taken off and a new set of bottles is put on. Two bottles on, two bottles off, two bottles on…

     

    Just a thought, but in the interest of price, what about a system drawing from the bottling tank (which already has its filters) and returning to the tank?  You'd probably need one more pump unless your tank is small enough for gravity return, but save the keg and filter.  

    This would also save priming the keg and cleaning two extra components when you're done (keg & filter).

    Heads and tails when using NGS

    in Beginners

    Posted

    12 hours ago, Roger said:

    There is no conceivable way that using a "lesser piece of equipment" and by that I mean a still that is not able to increase the proof of an alcohol, can remove anything at all from an already produced NGS. 

     

    with that said, I am assuming the question asked was I reference to a pot still, not a column that had the capacity to change the actual makeup of the distillate.

    prost. 

    NGS is produced using a fundamentally different piece of equipment than a batch pot still.  A pot still can very definitely improve NGS since a continuous system can not remove all heads.

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