EZdrinking
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Posts posted by EZdrinking
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If you are still having any issues please admin@distilling.com and Christy will help you get into the system.
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On 6/9/2020 at 5:34 PM, PeteB said:
There was so much interest after the show that it crashed my website.
Great news about the increased interest.
"Lots of emails enquiring about me shipping to USA but as most of you know your laws do not allow it. My online store automatically locks out USA addresses."
Does this mean US Importation soon? Fingers crossed on my end.
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FDA is requiring DSPs that are producing Hand Sanitizer to register here: https://www.fda.gov/drugs/drug-registration-and-listing-system-drls-and-edrls/electronic-drug-registration-and-listing-instructions
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Here is a link to the FDA's updated guidance on compounding Hand sanitizer
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Are you offering this as a free service?
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@Tailwinds @bluefish_dist and @Storm King Distilling Co. it is commonly said among tequila and mezcal distillers that most of the methanol comes off the still during the tails. I am curious if any of you have had this experience when distilling agave syrup?
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On March 27, 2020, President Trump signed into law the CARES Act, which provided additional assistance for small business owners and non-profits, including the opportunity to get up to a $10,000 Advance on an Economic Injury Disaster Loan (EIDL). This Advance may be available even if your EIDL application was declined or is still pending, and will be forgiven.
If you wish to apply for the Advance on your EIDL, please visit www.SBA.gov/Disaster as soon as possible to fill out a new, streamlined application. In order to qualify for the Advance, you need to submit this new application even if you previously submitted an EIDL application. Applying for the Advance will not impact the status or slow your existing application.
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For anyone looking to apply for SBA Disaster Loan Assistance you can do so here via this .gov website
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1 hour ago, Thatch said:
Okay, the new FDA guidance just posted a few minutes ago by the forum moderator is allowing distillers to make hand sanitizer and the FDA says they will not prosecute us for making it. BUT, it has to be DENATURED.
Here's the new doc
This update was also added to the other discussion thread.
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ADI does not administer the DISCUS website or its content. Any concerns about the DISCUS resource page should be directed to them.
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Part A provides a practical guide for use at the pharmacy bench during the actual preparation of the formulation. Users may want to display the material on the wall of the production unit.
Part B summarizes some essential background technical information and is taken from WHO Guidelines on Hand Hygiene in Health Care (2009). Within Part B the user has access to important safety and cost information and supplementary material relating to dispensers and distribution.
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TTB Public Guidance
Production of Hand Sanitizer to Address the COVID-19 Pandemic
March 26, 2020
TTB G 2020-1ASummary
Tax-free ethanol may be used to produce hand sanitizer if it is denatured according to TTB regulations and Food and Drug Administration (FDA) guidance.
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.
TTB is temporarily waiving certain formula approvals for the manufacture of hand sanitizer using and expediting certain permit requirements.
Purpose
On March 18, 2020, to facilitate the production of hand sanitizer, TTB temporarily relieved distilled spirits permittees of certain requirements related to the use of alcohol for this nonbeverage purpose (see TTB G 2020-1 “Production of Hand Sanitizer to Address the COVID-19 Pandemic”). TTB exempted permittees from obtaining formula approval from TTB before producing hand sanitizer if using a formula consistent with World Health Organization (WHO) guidance. Ethanol is one of the approved reagents in the WHO guidance. TTB’s March 18 authorization referred to both denatured and undenatured ethanol. However, on March 23, 2020, the FDA issued guidance which specifies the use of denaturants when compounding ethanol-based hand sanitizers. See Temporary Policy for Preparation of Certain Alcohol-Based Hand Sanitizer Products During the Public Health Emergency (COVID-19). TTB is therefore providing this guidance to (1) supersede its prior guidance with regard to the authorized formula to be consistent with FDA guidance; (2) exempt distilled spirits plants (DSPs) from the requirements to request approval from TTB to receive denatured or undenatured distilled spirits in bond from another DSP and to obtain additional bond coverage, through June 30, 2020; (3) provide guidance and certain exemptions from requirements for state and local governments wishing to obtain tax-free alcohol, and (4) offer hospitals, blood banks, sanitariums, certain pathological laboratories, non-profit clinics, and qualifying educational institutions the same streamlined application process.
This guidance also restates the provisions of TTB G 2020-1 that remain unchanged.
Guidance
Due to the Coronavirus 2019 (COVID-19) pandemic, the Acting Administrator of the Alcohol and Tobacco Tax and Trade Bureau (TTB) has found it desirable to waive provisions of internal revenue law with regard to distilled spirits, and therefore is providing certain exemptions and authorizations to distilled spirits permittees who wish to produce ethanol-based hand sanitizers to address the demand for such products during this emergency. Any existing DSP therefore can immediately commence production of hand sanitizer or distilled spirits (ethanol) for use in hand sanitizer, as described below, without having to first obtain authorization. Any existing DSP also may remove undenatured or denatured ethanol from bonded premises free of tax for use by any state or local government to produce hand sanitizer. 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. See 26 U.S.C. 5214(a)(3). These measures are generally authorized under authorities that apply in disaster situations, and as a result, are initially approved through June 30, 2020, with the possibility for extension as necessary.
Although TTB is exempting industry members from certain tax requirements through this guidance, industry members must continue to comply with other federal and state law, and industry members should contact relevant federal or state agencies with questions about guidance issued by those agencies.
Permit guidance for alcohol fuel plants (AFPs) and beverage DSPs: TTB is exempting AFPs and beverage DSPs from the requirement to obtain additional permits or bonds to manufacture hand sanitizer or to supply ethanol for use in the manufacture of hand sanitizer to other TTB permittees who are authorized to receive such distilled spirits. TTB is authorizing this exemption under 26 U.S.C. 5562. AFPs and beverage DSPs must continue to keep records of their operations, including any undertaken as authorized under this exemption.
Tax guidance for the manufacture of hand sanitizer: Nonbeverage products made with ethanol, including hand sanitizer, are not subject to federal excise tax. Please note that the FDA guidance referenced above specifies the use of denaturants when compounding hand sanitizer. For information regarding denaturants, please contact FDA.
Formula guidance for the manufacture of hand sanitizer: TTB is authorizing the manufacture of hand sanitizer products by DSPs using a formulation in the FDA guidance cited above without first obtaining formula approval from TTB.
Guidance for industrial alcohol users: Industrial alcohol user permittees may also use denatured ethanol to manufacture hand sanitizer using a formulation in the FDA guidance cited above without first obtaining formula approval from TTB. During the period covered by this guidance, TTB is also exempting industrial alcohol user permittees from the requirement to request approval from TTB to increase the quantities of denatured ethanol that they may procure. See 27 CFR 20.42(a)(3), 20.56. TTB is authorizing these exemptions under its authority in 27 CFR 20.22(b) to approve emergency variations from regulatory requirements.
Guidance regarding transfers in bond. Under current TTB regulations, when DSPs want to receive either denatured or undenatured ethanol from another domestic DSP, the receiving DSP must submit an application to TTB for authorization prior to the first transfer and ensure appropriate bond coverage. See 27 CFR 19.403, 404. During the period covered by this guidance, for transfers of either denatured or undenatured distilled spirits between domestic DSPs, TTB is exempting DSPs from the requirements to request approval from TTB to receive denatured or undenatured distilled spirits from another DSP and to obtain additional bond coverage. Rather than submit such requests to TTB for approval using TTB F 5100.16, DSPs must maintain records of such receipts, which would include records of the information currently required on TTB F 5100.16. TTB is authorizing these exemptions under its authority in 27 CFR 19.28 to approve emergency variations from regulatory requirements.
Guidance for state and local governments. Both denatured and undenatured alcohol may be removed free of tax for the use of a state, any political subdivision of a state, or the District of Columbia, for nonbeverage purposes, including making hand sanitizer. See 26 U.S.C. 5214(a)(2). An alcohol user permit is required to obtain alcohol from a distilled spirts plant. See 26 U.S.C. 5271(a); 27 CFR part 22. TTB provides state and local governments with a streamlined application, as authorized under 27 CFR 22.42 and 22.43(a)(1). TTB has dedicated personnel to process such applications seven days a week given the COVID-19 emergency. Please note that the recent FDA guidance cited above specifies using denaturants when compounding hand sanitizer. During the period of this guidance, TTB is authorizing state and local government permittees to make hand sanitizer for use anywhere, as needed to address the COVID-19 national emergency. See 27 CFR 22.22(b).
Guidance for hospitals, blood banks, sanitariums, certain pathological laboratories, non-profit clinics, and qualifying educational institutions. Hospitals, blood banks, sanitariums, certain pathological laboratories, non-profit clinics, and qualifying educational institutions may obtain alcohol free of tax for their own nonbeverage purpose use and not for resale or use in the manufacture of any product for sale, as described in 26 U.S.C. 5214(a)(3). Manufacturing hand sanitizer is one such nonbeverage use. As with state and local governments, such alcohol must be obtained from a distilled spirits plant and may only be obtained by those holding an alcohol user permit from TTB. See 26 U.S.C. 5271(a); 27 CFR part 22. TTB will offer these organizations the same streamlined application, as authorized under 27 CFR 22.42 and 22.43(a)(2). Again, please note that recent FDA guidance specifies using denaturants when making hand sanitizer.
Further Information
If you have questions regarding obtaining a TTB permit, please contact the National Revenue Center at 877-882-3277 / 877-TTB-FAQS (toll free) or online. For all other inquiries, please contact the Regulations and Rulings Division at 202-453-2265 or online. Please visit the homepage of TTB.gov for the most recent TTB news on COVID-19 related issues.
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DISCUS has put together a resource page for distillers here: https://www.distilledspirits.org/distillers-responding-to-covid-19/
Our COVID-19 Hand Sanitizer Connection Portal is a resource for distillers looking to produce hand sanitizer – providing a list of the necessary ingredients and supplies for making sanitizer and identifying distribution methods.. The portal is available for ALL American distillers to access.
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Updated FDA Guidence 3/24/20
This guidance is being issued to address the Coronavirus Disease 2019 (COVID-19) public health emergency. This is being implemented without prior public comment because FDA has determined that prior public participation for this guidance is not feasible or appropriate (see section 701(h)(1)(C)(i) of the Federal Food, Drug, and Cosmetic Act (FD&C Act) and 21 CFR 10.115(g)(2)). This guidance document is being implemented immediately, but it remains subject to comment in accordance with the Agency’s good guidance practices.
Download full doc below.
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FDA is issuing this guidance for immediate implementation in accordance with 21 CFR 10.115(g)(2). Comments may be submitted at any time for Agency consideration. Submit written comments to the Dockets Management Staff (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20852. Submit electronic comments to https://www.regulations.gov. All comments should be identified with the docket number listed in the notice of availability that publishes in the Federal Register. For questions regarding this document, contact FDA’s human drug compounding team (CDER) at compounding@fda.hhs.gov. U.S. Department of Health and Human Services Food and Drug Administration Center for Drug Evaluation and Research (CDER) March 2020
https://www.fda.gov/media/136118/download
Hand-Sanitizers-Immediately-in-Effect-Guidance-3-20-2020-345pm.pdf
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Hello all,
Christopher Carlsson of Spirits Review sent me the following link to share. It is aggregation of 118 plastic bottle suppliers from around the country. He knows people are looking for suppliers for he wanted to pass this on. https://www.thomasnet.com/products/custom-plastic-bottles-96102611-1.html
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Hi Tina,
You might want to talk to @Quirk from Cardinal Spirits.
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Special Edition - COVID-19
Production of Hand Sanitizer by Distilled Spirits Permittees
Greetings! This special edition contains guidance for DSPs and Industrial Alcohol User permittees on producing ethanol-based hand sanitizers.
Due to the Coronavirus 2019 (COVID-19) pandemic, the Acting Administrator of the Alcohol and Tobacco Tax and Trade Bureau (TTB) has found that it is necessary or desirable to waive provisions of internal revenue law with regard to distilled spirits, and therefore is providing certain exemptions and authorizations to distilled spirits permittees who wish to produce ethanol-based hand sanitizers to address the demand for such products during this emergency. Any existing DSP therefore can immediately commence production of hand sanitizer or distilled spirits (ethanol) for use in hand sanitizer, as described below, without having to obtain authorization first. These measures are generally authorized under authorities that apply in disaster situations, and as a result, are initially approved through June 30, 2020, with the possibility for extension as necessary.
Permit guidance for alcohol fuel plants (AFPs) and beverage distilled spirits plants: TTB is exempting AFPs and beverage DSPs from the requirement to obtain additional permits or bonds to manufacture hand sanitizer or to supply ethanol for use in the manufacture of hand sanitizer to other TTB permittees who are authorized to receive such distilled spirits. TTB is authorizing this exemption under the authority of 26 U.S.C. 5562. AFPs and beverage DSPs must continue to keep records of their operations, including any undertaken as authorized under this exemption.
Tax guidance for the manufacture of hand sanitizer: Hand sanitizer products are not subject to Federal excise tax if made with denatured ethanol. However, if made with undenatured ethanol, Federal excise tax applies. For information regarding denaturants, please contact TTB’s Scientific Services Division.
Formula guidance for the manufacture of hand sanitizer: TTB is authorizing the manufacture of hand sanitizer products consistent with World Health Organization (WHO) guidance. All TTB-permitted DSPs (including AFPs and beverage DSPs) may manufacture hand sanitizer products that are comprised of denatured or undenatured ethanol, glycerol (not less than 1.45% of the finished hand sanitizer product on a volume basis), and hydrogen peroxide (not less than 0.125% of the finished hand sanitizer product on a volume basis), without first obtaining formula approval from TTB.
Guidance for industrial alcohol users: Industrial alcohol user permittees may also use denatured ethanol to manufacture hand sanitizer consistent with World Health Organization (WHO) guidance without first obtaining formula approval. During the period of this guidance, TTB is also exempting industrial alcohol user permittees from the requirement to request approval from TTB to increase the quantities of denatured ethanol that they may procure (see 27 CFR 20.42(a)(3) and 20.56). TTB is authorizing these exemptions under its authority in 27 CFR 20.22(b) to approve emergency variations from regulatory requirements.
This information is available on our Public Guidance page.
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Special Edition - COVID-19
Production of Hand Sanitizer by Distilled Spirits Permittees
Greetings! This special edition contains guidance for DSPs and Industrial Alcohol User permittees on producing ethanol-based hand sanitizers.
Due to the Coronavirus 2019 (COVID-19) pandemic, the Acting Administrator of the Alcohol and Tobacco Tax and Trade Bureau (TTB) has found that it is necessary or desirable to waive provisions of internal revenue law with regard to distilled spirits, and therefore is providing certain exemptions and authorizations to distilled spirits permittees who wish to produce ethanol-based hand sanitizers to address the demand for such products during this emergency. Any existing DSP therefore can immediately commence production of hand sanitizer or distilled spirits (ethanol) for use in hand sanitizer, as described below, without having to obtain authorization first. These measures are generally authorized under authorities that apply in disaster situations, and as a result, are initially approved through June 30, 2020, with the possibility for extension as necessary.
Permit guidance for alcohol fuel plants (AFPs) and beverage distilled spirits plants: TTB is exempting AFPs and beverage DSPs from the requirement to obtain additional permits or bonds to manufacture hand sanitizer or to supply ethanol for use in the manufacture of hand sanitizer to other TTB permittees who are authorized to receive such distilled spirits. TTB is authorizing this exemption under the authority of 26 U.S.C. 5562. AFPs and beverage DSPs must continue to keep records of their operations, including any undertaken as authorized under this exemption.
Tax guidance for the manufacture of hand sanitizer: Hand sanitizer products are not subject to Federal excise tax if made with denatured ethanol. However, if made with undenatured ethanol, Federal excise tax applies. For information regarding denaturants, please contact TTB’s Scientific Services Division.
Formula guidance for the manufacture of hand sanitizer: TTB is authorizing the manufacture of hand sanitizer products consistent with World Health Organization (WHO) guidance. All TTB-permitted DSPs (including AFPs and beverage DSPs) may manufacture hand sanitizer products that are comprised of denatured or undenatured ethanol, glycerol (not less than 1.45% of the finished hand sanitizer product on a volume basis), and hydrogen peroxide (not less than 0.125% of the finished hand sanitizer product on a volume basis), without first obtaining formula approval from TTB.
Guidance for industrial alcohol users: Industrial alcohol user permittees may also use denatured ethanol to manufacture hand sanitizer consistent with World Health Organization (WHO) guidance without first obtaining formula approval. During the period of this guidance, TTB is also exempting industrial alcohol user permittees from the requirement to request approval from TTB to increase the quantities of denatured ethanol that they may procure (see 27 CFR 20.42(a)(3) and 20.56). TTB is authorizing these exemptions under its authority in 27 CFR 20.22(b) to approve emergency variations from regulatory requirements.
This information is available on our Public Guidance page.
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New guidance for DSPs producing hand sanitizer is coming from TTB. In the meantime here is some information from DISCUS and WHO.
It looks like TTB and FDA are going to waive some of the legal requirements during this current shortage.
Hand Sanitizer WHO Formula.xlsx DISCUS Guidance_Hand Sanitizer_20.3.17.pdf
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New guidance for DSPs producing hand sanitizer is coming from TTB. In the meantime here is some information from DISCUS and WHO.
@Hudson bay distillers & @Skaalvenn it looks like TTB and FDA are going to waive some of the legal requirements during this current shortage.
Hand Sanitizer WHO Formula.xlsx DISCUS Guidance_Hand Sanitizer_20.3.17.pdf
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ADI is looking for a craft distiller with established brands, who is looking to rebrand, and would like to participate in our "Ask the Experts: Branding Webinar". If interested, go to https://distilling.com/event/branding-webinar/ to check out the description of the webinar, and contact eriko@distilling.com.
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On 3/4/2020 at 5:36 AM, MaconBooze said:
the tour guide said that it was not distilled on-site! They had a (very) large Midwestern distillery make up their mash bill, ship them the distilled spirits, and then they barreled and aged them on-site....How can a spirit be called 'Bottled in Bond'
As far as I am award this should not be labeled as Bottled in Bond. And @dhdunbar is correct that what some things should be labeled and what TTB approves are not always the same thing. If I remember correctly Bourbon does not require formula approval so maybe that was why TTB approved the label when the spirit was not distilled at the DSP where whiskey was aged.
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ADI
ACSA
SF Worlds Spirits (you may need to pay for the medals)
Great American International Spirits Competition
Sunset International Spirits Competition
SIP Northwest
Good Food Awards
...
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Virtual Public Policy Conference - Free of Charge
in ADI News & Events
Posted
The annual Public Policy Conference will be a virtual event this year and you can register for free through Eventbrithe here: https://www.eventbrite.com/e/public-policy-conference-registration-111854092602
I flew out to DC last year and it was a privilege to participate and speak to representatives about the needs of the craft distilling community. Since this year's even is virtual and free of charge, I would encourage as many US distillers as possible to participate. Speak directly with your representatives and remind them of the importance of making the FET reduction permanent, the need to end tariffs that effect US spirits and any other regulatory/tax issues effecting your business.