Transfer in Bond question please help!

[Papis Coquito]

Hi everyone, 

 

I'm new to liquor branding and have worked on everything including a co-packer and money to start production, flavor, etc. My problem is with my Co-packer, hes been acting real shady. His LLC just dissolved back in June he says its from not filing his Annual report in two years (I know red flag). But now we are ready to start production and he keeps saying im submitting your labels and formula "today" almost every day for two months now. I'd hate to try and find another co packer when all we need is him to get his act together. So my question is, I have a Wholesaler License for spirits why cant I submit a TIB myself? I mean technically my license allows me to buy and sell alcohol at wholesale.  

[Silk City Distillers]

What’s the TIB have to do with formula and label submissions?  Not following.

Look on the bright side, far easier to find another producer now, than to try to unwind this relationship after you’ve got sales and orders in the pipeline going unmet.  You trying to get this going for this holiday season?

Traditional recipe?  I get how that’s going to be a challenge for a typical co-packer who are used to very typical blend and bottle ops.  Tried to get something going with a local coquito producer a few years back, shelf stability issues, separation issues, the need to actually cook ingredients, refrigeration requirements, lots of gotchas.  Tried to get him to consider a cream base from Creamy Creation, it was like I was insulting his grandmother.

[GBDistillers]

On 9/27/2021 at 11:38 PM, Papis Coquito said:

Hi everyone, 

 

I'm new to liquor branding and have worked on everything including a co-packer and money to start production, flavor, etc. My problem is with my Co-packer, hes been acting real shady. His LLC just dissolved back in June he says its from not filing his Annual report in two years (I know red flag). But now we are ready to start production and he keeps saying im submitting your labels and formula "today" almost every day for two months now. I'd hate to try and find another co packer when all we need is him to get his act together. So my question is, I have a Wholesaler License for spirits why cant I submit a TIB myself? I mean technically my license allows me to buy and sell alcohol at wholesale.  

Your best bet is to find another co-packer, if he didn't submit formulas and labels yet. Formulas is taking about 5 to 7 days for approval and labels about the same . Ive been submitting all last month and getting it them really fast. Also, wholesalers Federal Base permit can't do a TIB, thats for DSP holders only.  Yeah, you can buy wholesale of a finish product but not if its a 192 proof Tote that needs to be proofed down or blended,  DSP has distlling , warehousing,  processing,  blending and rectifying privileges with the insurance, bonding and equipment to back it up. 

Hope that helps.