Liqueurs without distillation

[Guest MC Mountain Man]

Hello,

  I enjoy buying cheap vodka or brandy and tincturing good fruit in it. Sometimes I add sugar syrup.  Either way I make amazing liqueurs and brandies. No distillation requires. I currently give these away as gifts to friends and family, but I would like to sell them. Are there any federal laws that would apply since I buy the vodka at retail?

 

Thank you,

MC Mountain Man

[FIVE x 5 Consulting]

12 hours ago, Guest MC Mountain Man said:

Hello,

  I enjoy buying cheap vodka or brandy and tincturing good fruit in it. Sometimes I add sugar syrup.  Either way I make amazing liqueurs and brandies. No distillation requires. I currently give these away as gifts to friends and family, but I would like to sell them. Are there any federal laws that would apply since I buy the vodka at retail?

 

Thank you,

MC Mountain Man

If you want to produce and sell the product within the 3 tier system (i.e. to wholesalers and/or bars/restaurants/liquor stores) then you'll need to qualify as a distilled spirit plant. The fact that you do not distill is not material to this analysis. Your infusion/tincturing is a processing activity that requires a Basic Permit (i.e. full-scale production permit).

A workaround that is legal in some states but not all would be to buy a bar and do your infusions behind the bar. Then you can sell them as mixed drinks. Some states even let you sell those mixed drinks to-go. This would entail getting a retail permit from you state/municipality.

Fundamentally, you will need SOME kind of licensing in order to legally sell alcohol, full stop.

[Kindred Spirits]

As 5X mentioned, you would need a location, outside of your house, to manufacture these products. 

You would also have to put some specifics on the label that reflect the process, such as "produced by XX" vs "Distilled by XX"

It would be much easier to make a small production space and be a legal distillery than do this with a bar.

If you have any questions, or would like to talk reach out to us on our website.

https://kindredspiritscsg.com/