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Does everyone need a DSP?


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I've addressed this before on these forums, in some detail.  Short answer here.  The answer that you need a basic permit as a processor and bottler is correct.  You also need to register the DSP under the IRC, get a bond, etc...

But you can't just have someone else bottle for you unless you know how to play that game.  If they distribute it for you, and you never take title, and they pay you a royalty on sales, then you don't need a permit as a wholesaler.  But  if you take title to bottled goods, you have to have a basic permit as a wholesale liquor dealer.

Here is the best advice I can give.  When you have a question like this, ask TTB to give you the answer.  Don't ask here.  When you get the answer, post it so others can see it.  Then have them call TTB to confirm what you've reported you heard, just in case what you heard was not what TTB actually said.  It happens.



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