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This is probably a question I've got to ask the TTB (and FDA), but just wanted to float this out here and see if anyone has dealt with anything similar.

I make a spiced honey liqueur (Krupnikas) that uses, among other stuff, lemon and orange zest. This results in quite a bit of pectin precipitating out in the final product. About 10% of the final blend is cloudy with spice particles and pectins. These are quite difficult to filter out. We could use a centrifuge (lots of $$$), or possibly a bag-type or rotary-drum filter, but all of those are scaled for operations larger than mine right now.

So I've just been saving this stuff, decanting off the clear part, and bottling that. Obviously this is not the ideal method and I'm trying to figure out whether I can afford to filter this stuff and recover the perfectly-useable product that's mixed in with the dregs. Pectin is really annoying to deal with, and it will quickly clog up any kind of typical filter media as it's a very 'sticky' but very small molecule. Essentially it just makes a gel when you try and pressurize it through anything.

The other route I'm considering is just using the stuff to make a food product of some kind. It's got a lot of flavor mixed in. Honey + spices = delicious is pretty basic math. At home on the stove I've made cakes and apple sauce using this stuff that were fantastic. But that means not only figuring out FDA regulations on this, but explaining to the TTB where it's going and finding out if I still owe excise taxes or not, etc. (have not researched this at all)

Even if I can filter out the stuff, those spice solids are still usable for flavoring, and pectins themselves have uses in the food processing industry as a thickener.

I'm just curious if anyone has done something similar with a spirits by-product, and what your experience dealing with those regulations has been. Or any other thoughts on this kind of thing.

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