TTB Production report question

[Pour Decisions]

First time running up against this scenario for my December TTB reports and doing these manually without one of the computer programs. I did a spirit run of whiskey, filled two 15 gallon barrels at 110 proof and filled 18 bottles of white dog. I also put some additional proofed down white dog in a stainless vessel for temporary storage while waiting on a bottle shipment. I know the barreled spirits go to storage, bottled as withdrawn for tax payment, but the remainder of the white dog, storage or processing?

[FIVE x 5 Consulting]

There's a quote from TTB's website stating: 

Quote

Generally, storage is when you hold bulk quantities of product without specific plans for further processing.

But there is no specific regulation I'm aware of that actually requires you to use Storage or Processing in any particular scenario.

The advice I will give here is therefore based not on regulation but on my personal opinion, informed by my experience.

I would show all of your white dog production on the Production report. The PGs that went into the two 15 gallon barrels would be deposited into cooperage in Storage. The remaining PGs would be Dumped into Processing Bulk (Pt I), without going through Storage first.

The quantity that you bottled would move to Processing Pt II while the quantity in stainless awaiting bottles would remain in Processing Pt I until you bottle it.

[Kindred Spirits]

Typically It is much easier to only move things to the processing side of things when you are wanting to bottle it. 

There isn't the same provisions as there are in the storage report for distinguishing the differences between what's there in the bulk or bottled section.

Pretty much the way I was taught to do them is, anything you make goes in "production", stuff that's just hanging out in the distillery in bulk form goes into storage, and bottled and tax withdrawn shows up on processing.

Its clear that 3 different people generated these forms at 3 different times, they really need to update them. All of the pertinent information could easily be compiled on 1 report sheet.

[Pour Decisions]

On 1/11/2024 at 9:18 AM, Kindred Spirits said:

Its clear that 3 different people generated these forms at 3 different times, they really need to update them. All of the pertinent information could easily be compiled on 1 report sheet.

I wholeheartedly agree, time to simplify the reporting!

[FIVE x 5 Consulting]

TTB asked for letters on that very topic last year, and not a lot of folks responded.

https://www.regulations.gov/document/TTB-2023-0005-0001