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System of Storage


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For the "system of storage" question in the permit for warehouseman and spirits bottled and cases, what are the TTB asking operationally?

Is this just whiskey storaged in barrells or bottles on a pallet, etc... Or does have to do with the marking of the spirits?

Any help would be appreciated.


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To amplify on my prior response and hopefully de-snark it a bit, the TTB is looking for a statement that mirrors their explicit directives in 27 CFR. There's no shortcut here. You do have to read it; or you can hire an attorney to read it for you (expensive). Once you have a grasp of the requirements, you have to craft a response that tracks their directives. There are a number of areas in the TTB process where a similar type of logic applies. It amounts to them asking, "are you paying attention to the rules." If you are; and you follow those dog whistles, you'll be in good shape.

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