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Botting Spirits / Vodka larger than 1.8L for a local Tincture Maker

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Hello, just wondering is their a TTB exception you can get to bottle say 1 gallon or 5 gallon totes of vodka?

I have a local tincture maker that would like to get our vodka in larger containers. 

They also would like to be able to rinse out the containers and bring them back to us to re-fill. 

Under current rules I have read looks like both these options are not possible.

Thanks for any advice!


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