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"Statement of production procedure" Question about permit?


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After speaking with a TTB representative, I felt I should come here for a bit more help. We are going to be a small distillery intending to produce a variety of products for sale exclusively at the distillery. Products we wish to make include but are not limited to: whiskey, rum, gin, vodka, fruit brandies & liqueurs, maybe even blue agave spirit. And flavored versions of the previous. I am a bit confused where the overlap is, if there is one, between the "statement of production procedure" on my application vs. formulas?

The TTB representative said to keep the descriptions on my application as simple as possible, that I don't need to be overly detailed on each product, and that if they need more information they will contact me. Sounds like a delay in the making!

Sooo, I'm looking for suggestions on the best way to be covered on basically anything I wish to make without writing an encyclopedia??

Thanks in advance for the help!!!


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The TTB rep is right.

First, not all of the products in your array require a statement of process.  You make a statement of process only for the spirits that come off the still after the final spirits run.  At that time you gauge them and designate them.  Basically, coming off the still, you will produce whiskey designate, neutral spirits, rum and brandy.  You could produce gin or vodka by original distillation, but most don't.  Each of those is a class of spirit, with the exception of vodka, which is a type within the neutral spirits class.

Next, everything you do after that is done in either storage or processing.  When you age brandy, rum, or whiskey in storage, you do not need a formual.  You do not change class and type.   

When you add flavorings, or harmless coloring or blending materials, or filter nsg to make vodka, or redistill nsg over aromatics to make gin, you change class and type.  That requires a formula.  Formulas are specifically for changes in class and type, with the exception of products that you will label as whiskey, without further type designation (bourbon, corn, whiskey distilled from malt mash, etc).  TTB requires a pre-COLA analysis of spirits labeled only with the classs whiskey.  The means you must submit a formula before you can get label approval.  Ask why whiskey and why not bourbon and they will tell you, its all that white whiskey out there.  That is, they want to make sure it gets aged, even if the aging is a minimal joke.If you have got away without a formula, then the specialist did not apply TTB's own rules when giving the approval.  

Formulas are much more detailed than statements of production procedure.  How did that come to be?  I suspect that the specialists who review the commodity applications, as TTB calls them, have little knowledge of the niceties of the standards of identity.  So they like simple explanations.  Formula specialists thrive on detail.  In part, this is because the FDA and TTB impose limits on certain ingredients, etc, and required GRAS certifications.  Some ingredients are prohibited altogether, and in the case of products like liqueurs, there are sugar considerations in determining whether it meets class and type standards.  Most of that does not come into play with statements of production procedures, although you can hang aromatics in the gin basket when you distill the beer. In that case, simplicity should not be TTB's accepted rule.  But it probably is.  

That is it in a nutshell.  And I don't go beyond the nut's shell, because who knows what nutty formulation TTB will and will not approve.  



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  • 3 weeks later...

The old application asked you to include "the kind and approximate quantity of each material or substance used in the process" harmonizing with CFR 19.77 a, however the current application no longer asks for this.

Has anyone run into a problem omitting specific quantities on their application?

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