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"Will Spirits Be Re Distilled" Question on Federal App?


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I am looking for a bit of clarification about this question on my application. It is my understanding that this question if specifically referring to bringing in spirits produced elsewhere and then distilled again by me, correct? This would NOT be referring to say, macerating  a neutral that I produced to make gin and running it through my still again?? I'm just trying to make sure. The TTB response I got was, "most distillers don't re distill."

Thanks in advance!!

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One possibility...

Q: How do I track or report Heads and Tails?
A: Records of heads and tails production, re-distillation, or destruction are for internal use only kept locally at the distillery. If you don’t re-use or re-distill heads and tails, make sure you are disposing of the spirits and recording the destruction locally in a way that is compliant with your local regulations. Heads and tails are considered Unfinished Spirits and are only reported to the TTB on the Production Report each Quarter on “Line 17 b. Unfinished Spirits” if you have a tank with heads or tails left over in a Production Tank at the end of the quarter. Most distilleries will physically do something with the heads and tails after each run and not leave any balance of or report Unfinished Spirits at the end of the Quarter.

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§ 19.316 Redistillation.

(a) TTB has established standards of identity for the various classes and types of distilled spirits. Those standards are found in part 5 of this chapter. If a proprietor intends to redistill spirits, the proprietor must ensure that the redistillation process does not cause the distillate to be become ineligible for designation in the class or type of spirits that the proprietor intends to produce. Therefore, spirits must not be redistilled at a proof lower than that allowed for the class and type at which the spirits were originally produced, unless the redistilled spirits are to be:

(1) Used in wine production;

(2) Used in the manufacture of gin or vodka; or

(3) Designated as alcohol.

(b) In order to preserve the class and type of spirits during the redistillation process, different kinds of spirits must be redistilled separately, or with distilling material of the same kind or type as that from which the spirits were originally produced. However, this restriction does not apply when:

(1) Brandy is redistilled into “spirits-fruit” or “neutral spirits-fruit”. In this case the resulting distillate must not be used for producing wine;

(2) Whiskey is redistilled into “spirits-grain” or “neutral spirits-grain”;

(3) Spirits originally distilled from different kinds of material are redistilled into “spirits-mixed” or “neutral spirits-mixed”; or

(4) The spirits are redistilled into alcohol.

(c) All spirits redistilled after the production gauge will be treated the same as if the spirits had been originally produced by the redistiller. Spirits recovered by redistillation of denatured spirits, articles, or spirits residues may not be withdrawn from bonded premises except for industrial use or after denaturation. Otherwise, all provisions of this part and 26 U.S.C. chapter 51 applicable to the original production of spirits will be applicable to the redistillation of spirits. Nothing in this section affects any provision of this chapter relating to the labeling of distilled spirits.

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