Labeling and business address

[Palmetto Coast]

I'm hoping someone can clarify something for me. One of the things I am considering is sub-contracting out some distilling until the distillery is built. This would allow me, among other things, to get samples for distributors and minimize overhead while I set up distribution.

Now here is my question... If the sub-contractor (don't worry, it is a micro-distillery) is in another state, how can I get MY address and company name on the label? Looking in the BAM, it would seem that I can not, but I may just be reading it wrong. It syates the following:

The name(s) and address(es) of the:

Bottler or

Packer or

Filler

AND/OR

Distiller or

Blender or

Maker or

Preparer or

Manufacturer or

Producer

However, if I am there during production and assisting, would that count? If it is produced FOR me, does that count? Would we need to file a DBA?

Or, would we use my company name and address as the principle place of business?

"The city and state of the bottler’s, packer’s, filler’s, distiller’s, etc.,

principal place of business (see PRINCIPAL PLACE OF BUSINESS

section of CHAPTER 5, NAME AND ADDRESS)"

Chapter 5 seems to address this, but I am not quite getting it.

"The name of the company for whom the distilled spirits were bottled, packed

or filled AND the principal place of business address of the company for

whom the distilled spirits are bottled, packed or filled. The contract bottler

may exercise this option only if:

The company for whom the distilled spirits are bottled, packed or filled is

qualified as a distilled spirits plant"

I will not have my DSP at that time.

Thanks for your help.

Todd

[Gwydion Stone]

You need the name of the DSP and its city on the label. A DBA would work best, but make sure you have everything clearly in writing regarding IP and ownership. You'd have the dsp add your company name to its license and submit that change to the TTB. Once its on their records, you're good to go.

[Wes Henderson]

Obtain your Basic Permit as a Wholesaler. Your bottler can then add your licensed company as a DBA, and this DBA name may appear on the label. It will, however, need to have the city and state of the bottler/producer on the label (but not their name).

Make sense?

wh

I'm hoping someone can clarify something for me. One of the things I am considering is sub-contracting out some distilling until the distillery is built. This would allow me, among other things, to get samples for distributors and minimize overhead while I set up distribution.

Now here is my question... If the sub-contractor (don't worry, it is a micro-distillery) is in another state, how can I get MY address and company name on the label? Looking in the BAM, it would seem that I can not, but I may just be reading it wrong. It syates the following:

The name(s) and address(es) of the:

Bottler or

Packer or

Filler

AND/OR

Distiller or

Blender or

Maker or

Preparer or

Manufacturer or

Producer

However, if I am there during production and assisting, would that count? If it is produced FOR me, does that count? Would we need to file a DBA?

Or, would we use my company name and address as the principle place of business?

"The city and state of the bottler’s, packer’s, filler’s, distiller’s, etc.,

principal place of business (see PRINCIPAL PLACE OF BUSINESS

section of CHAPTER 5, NAME AND ADDRESS)"

Chapter 5 seems to address this, but I am not quite getting it.

"The name of the company for whom the distilled spirits were bottled, packed

or filled AND the principal place of business address of the company for

whom the distilled spirits are bottled, packed or filled. The contract bottler

may exercise this option only if:

The company for whom the distilled spirits are bottled, packed or filled is

qualified as a distilled spirits plant"

I will not have my DSP at that time.

Thanks for your help.

Todd

[Palmetto Coast]

Thanks for clearing that up for me!

Todd