registration of still?

[Sorghumrunner]

We had a local fabrication shop build a stripping still of our design. Reading CFR 29.47 it looks as though they were supposed to send the TTB a letter stating:

(1) The name and address of the manufacturer;

(2) The name and complete address of the person by whom the apparatus is to be used, and of any other person for, by, or through whom the apparatus is ordered or disposed of;

(3) The distilling purpose for which the apparatus is to be used (distillation of spirits, redistillation of spirits or recovery of spirits, including denatured spirits and articles containing spirits or denatured spirits);

(4) The manufacturer's serial number of the apparatus;

(5) The type and kind of apparatus;

(6) The distilling capacity of the apparatus; and

(7) The date the apparatus is to be removed from the place of manufacture.

Is this all that they will need to do? I don't believe that they will be manufacturing more of these, as they typically are producing biodiesel production equipment.

[jheising]

Sorghumrunner,

As I understand it, the key to CFR 29.47 is the part that says "When required by letter issued by the appropriate TTB officer"— meaning that the TTB only requires the manufacturer to furnish this information IF they ask them to. So it's something the TTB has to initiate, not the manufacturer. Anyway this is just my understanding and it never hurts to Email the TTB and ask them to clarify.

Cheers,

-jim

[Dehner Distillery]

Correct you only need to supply the name of the person or company if the TTB ask for it.

You just need to keep the info on file for you. Don't send anything in.

Joseph

Master Distiller

Dehner Distillery

[Jedd Haas]

You just need to keep the info on file for you. Don't send anything in.

The supplemental pages for TTB form F 5110.41 asks for a list of "major equipment." That's where you would send it in. If you built it yourself, you assign your own serial number.

[Bier Distillery]

If you update your major equipment after you are registered and operating what exactly do you need to do? Resend the supplemental page? When? Immediately or next time the registration form is sent in? Do you need to wait for a response before using the equipment?

[CopperPig]

They really just want the serial numbers, type of equipment and size from you.

[Bier Distillery]

Right, but how exactly do I notify them? When? Do I need to hear back before using the equipment?

Here's what a TTB presentation says:

Change in Construction or Use of Buildings and

Equipment

• When a change in construction or use of

buildings and equipment(other than changes

to or alternating premises) occurs:

– Prior to change – file letter notice

– Must incorporate changes on the next amended

registration TTB F 5110.41 filed

27 CFR 19.193

What does this letter need to look like? "#XY1234656, column reflux, 123 gallons"? Just that? Updated drawing, or does that wait for the next [yearly?] registration?

[CopperPig]

Having just gone through my DSP submittal and process recently, we included it under the bonded area/POC description, and process description. Once you are permitted and they have given you permission to operate, you are welcome to move things around and change basic equipment...just leave everything as is as listed on paper till you are "all clear." I haven't amended any registration items yet, so I can't help you beyond that. The TTB field office number(s) are a great resource and the folks are actually responsive and informative, at least the West Coast office is. http://www.ttb.gov/about/locations.shtml