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Bonding/Warehousing Barrels


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We are looking at a relatively small location.The size is big enough for running out equipment and a limited amount of barrels. The space offers two solutions:

1. It has a few smaller spaces (same building but not directly next door) which would be ideal for a barrell room. Once we need more space, we could cheaply rent a space to store barrels.

2. It has a large secure basement area with racks which we can utilize free. Not the best option because its pretty chilly there year round which may lengthen aging time.

My question is whether I can expand a bond to add space in the same building in the future? Has anyone run into this?

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Yes, you may expand to add space. It is called noncontiguous premises and here are the provisions that apply:

Sec. 19.53 Continuity of plant premises.

As a general rule, the premises of a distilled spirits plant must be continuous except for separations by public waterways, roads, or carrier rights-of-way. However, the appropriate TTB officer may approve the registration of the plant where there are separations of the plant premises and all parts of the plant are in the same general location if:

(a) There is no jeopardy to revenue caused by the separation of premises; and

(B) The separation of premises does not create administrative problems for TTB.

TTB's guidelines on this change from time to time. I've not asked recently. The most recent public comment I've seen was in the Treasury Decision that announced the changes to Part 19 in 2011:

TTB Response: In the preamble to Notice No. 83, we explained that we would not adopt a 200-mile rule and the current comment does not provide sufficient justification for any change of our position. We will continue to evaluate requests for alternate methods or procedures concerning plant continuity on a case-by-case basis, each analysis to be based upon multiple factors. Generally, we believe that the ‘‘same general location’’ must not be too large an area so that the revenue is placed at risk. Also, because a distance of 200 miles could extend over a multi- state area and would cross over into different field offices within TTB, such a distance would create administrative difficulties for TTB.
I've heard urban legends that the distiance is not more than 10 miles. I do not trust urban legends.
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My DSP is located in a village setting. I originally applied for a building on my farm, which is 13 miles away, to be included as an off site location to house my Mash operation and barrel storage. I included a Google earth map of the location and route between the two. It was approved right along with the original application.

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