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Posted

If you buy spirits in bulk, and then bottle them in your facility, what equipment is required to get a DSP license? Obviously you don't need a still to finish the product, but would you have to get one anyways in order to comply with the TTB?

Posted

Sorry I don't remember the answer to this, but as a follow up to your other question, you don't need an operation license to get going.  You could have the product bottled for you and you could just get a license to warehouse I believe.

Posted
13 minutes ago, jeffw said:

Sorry I don't remember the answer to this, but as a follow up to your other question, you don't need an operation license to get going.  You could have the product bottled for you and you could just get a license to warehouse I believe.

Okay good to know! What if we wanted to make adjustments to the spirits we purchase? Would that make us a rectifier/require a DSP license?

Posted

Licenses, permits, registrations.  

Okay - we need to review the ABC's of distilled spirits plants.  First, you do not need to have a still to be a distilled spirits plant.  There are three kinds of DSP operations. They are production (distilling), warehousing (storing bulk spirits) and processing ("making adjustments, " as you put it, or bottling).  Any of these operations must be conducted on distilled spirits plant bonded premises.  

You can qualify in a number of ways.  Basically, you can qualify for any combination of the three, but you cannot qualify to process only (to process you must be either a distiller and processor, or warehouse man and processor, or distiller, warehouse man and processor).

Now, if you get product bottled for you, and that is all you do, then you are not going to qualify as a DSP, because (1) bottled spirits cannot be transferred in bond and (2) you therefore are not engaged in any distilled spirits plant operations (distilling, warehousing, or bottling spirits on which tax has not been paid or determined).

If you buy bottled spirits for resale at wholesale, you have to get a basic permit as a wholesaler, not as a DSP.  

If you buy bulk spirits to bottle yourself, then you would need to qualify as distilled spirits plant that warehouses and processes.  Bottling is a processing operation, but remember the rule, you may not be just a processor.  

A basic permit and registration for warehousing operations only allows you to store bulk spirits, as in a storage area for barrels, and nothing else.

What are bulk spirits?  They are spirits in containers of one gallon or more.  It is illegal for a DSP to ship bulk spirits, other than industrial alcohol, to anyone who is not qualified as a distilled spirits plant.

You can trace through all of this by looking at the definitions in part 19 and the basic permit requirements of part 1.

It is important that you understand these basics.  And yes, mucking about with the spirits makes you a "rectifier," a term that now appears only in part 1.  Strip it from your language when you talk about distilled spirits plants.  Substitute processor.  

Forgive me, but to advertise shamelessly - which I don't often do on these forums, where I offer advice for free - these are the kinds of issues I spend a day discussing at SIPS training.  Check it out if you are interested.                                                         

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