TTB/Fed Law on Distribution of kegged RTD Cocktails

[BarrySideShow]

Looking for any help or experience with distribution of kegged cocktails.   We just released our first foray into RTDs and were planning to release these in kegs as well to bars and restaurants around the state when... whoops we maybe didn't do our research fully.   

We made a call to TTB due to Standards of Fill and were told that distributing RTD Cocktails in kegs is "probably not allowed".   Perfect clarity.   We were told that there are some changes that are/have happened with Standards of Fill and we could "probably" get around that but there is a 1 gallon limit that would require a change to Federal Law.   We are aware of a few RTD kegged cocktails being distributed in our area, so we would like to believe this is being done legally, but haven't been able to find the right information.   

Any help or point in the right direction would be much appreciated.

[Stumpy's]

Standard of fill is definitely the issue. Largest container allowable is a 1.75L. Generally, kegs are either built on site at accounts in soda style kegs or there is some sort of patented mechanism/process to get alcohol into a sanke-d style keg after everything has been run through the 3-tier system. The problem with the soda style keg is that it requires draft line conversion, cleaning (who does it and how often) and the account can honestly put whatever the heck they want in it. We take the second approach with a methodology we developed. One thing you do need to be careful about is state law on who can and cannot make a cocktail. In one state we distribute in, the supplier and "build" the keg at the account under the account's supervision. In another state we distribute in, the account must do everything themselves. Kegged cocktails are a bit of a gray area right now but make sure to do your due diligence before you start and understand all of your state-by-state restrictions and guidelines.