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Processing Report, Packaging, and Importing


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Hey all,

I have a couple of questions on the processing report:

- Part II:

Finished Products, what constitutes a packaged product?

- Under part IV C,D,E, and F

Do you need to put packaged products in this category as well, or only bottled? If no, is there a location where finished packaged products go?





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Chris - quickly. As a distilled spirits plant dealing in beverage alcohol, it is unlikely that you will have packaged products. Both bottles and packages are containers. A container is "A receptacle, vessel, or form of bottle, can, package, tank or pipeline (where specifically included) used or capable of being used to contain, store, transfer, convey, remove, or withdraw spirits and denatured spirits. A package is "A cask or barrel or similar wooden container, or a drum or similar metal container." Both of those definitions appear in Section 19.1. Bottles are liquor bottles. 191. defines a liquor bottle as "A bottle made of glass or earthenware, or of other suitable material approved by the Food and Drug Administration, which has been designed or is intended for use as a container for distilled spirits for sale for beverage purposes and which has been determined by the Administrator to adequately protect the revenue." More succinctly, they are the bottles into which you place your spirits. Pat 19 includes an entire subpart devoted to liquor bottles. See the requirements there.

I've just responded to our question about imported spirits with a rather lengthy discussion of why you have to learn how to classify. I will not repeat that here. Classification is an act of definition. Learning to classify is learning how to apply definitions to a set of rules.

Good luck.

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