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Posted

in CFR 19.490 is the "series" product specific for case and/or bottle numbers?   If a company has 2 products, A and B, would the first 10 cases/bottles of each follow as product A: 1-10 product B: 11-20 or are both A and B: 1-10 case/bottles?

 

Thanks

Posted

Yup. The incrementing serial number is unique, across all products at the DSP. But you can add additional identifiers, so your numbers in your example could be: A-0001 to A-0010 and B-0011 to B-0020, for example.

Posted

Is it just me, or are many of the big DSPs not numbering their cases?  I've picked up a few cases from liquor stores and been unable to find a DSP# or case # on many of them.

Posted
On September 3, 2016 at 11:25 AM, Skaalvenn said:

Is it just me, or are many of the big DSPs not numbering their cases?  I've picked up a few cases from liquor stores and been unable to find a DSP# or case # on many of them.

The serial number might sometimes be an ink jet printed number somewhere on the case, not obvious. And some big distillers put a serial number on the bottle, I think if you do that, you don't need to have it on the case. Also, without a serial number on case or bottle it becomes almost impossible to have in place an executable recall procedure, which is required.

Posted

We have batch numbers on the bottle. With that we can do a recall, but it's especially handy in working to improve product over time.

Posted
4 hours ago, Skaalvenn said:

We have batch numbers on the bottle. With that we can do a recall, but it's especially handy in working to improve product over time.

Batch numbers or barrel numbers are certainly good quality control, and aid in a recall. But they are not bottle serial numbers, and therefore not a replacement for case serial numbers. Sounds like you need the case serial numbers too. And include them in your recall plan.

Posted
Quote

§19.490   Numbering of packages and cases filled in processing.

(a) Packages of spirits and denatured spirits filled during processing operations. When a proprietor fills packages of spirits and denatured spirits during processing, the proprietor must identify the packages consecutively beginning with “1” and continuing the series until the number “1,000,000” is reached, except that any series of such numbers already in use may be continued to that limit. When the identification in any series reaches “1,000,000”, the proprietor may begin a new series with “1” but must add an alphabetical prefix or suffix to the new series number. For example, the first identifier in the second series of 1,000,000 packages filled might be “1A” or “A1”.

(b) Cases containing bottles or other containers of spirits and denatured spirits. When a proprietor fills cases containing bottles or other containers of spirits and denatured spirits during processing, the proprietor must identify the cases consecutively beginning with “1” and continuing the series until the number “1,000,000” is reached, except that any series of such numbers already in use may be continued to that limit. When the identification in any series reaches “1,000,000”, the proprietor may begin a new series with “1”. This series of identifiers for cases containing bottles or other containers must be distinct from the series of serial numbers required for packages under paragraph (a) of this section.

(c) Additional identification. A proprietor may establish separate series of identifiers, distinguished from each other by the use of alphabetical prefixes or suffixes, to identify the size of bottles, the brand names, or other information, on written notice to the appropriate TTB officer. The proprietor must identify remnant cases by placing the identifier of the last full case followed by the letter “R” on the remnant case. When there is a change in the name, or trade name of the proprietor, all series in use may be continued. However, if there is a change in proprietorship, a new series must be commenced.

(d) Alternative marking for spirits for industrial use. A proprietor may mark packages and cases of spirits for industrial use, including denatured spirits, filled in processing with the lot identification numbers specified in §19.485 instead of using the identifiers specified in paragraphs (a), (b) and (c) of this section

Oh dear. We had read that to allow A: 1-10 and B: 1-10, but going back I don't see any text to do so. I think "except that any series of such numbers already in use may be continued to that limit" is where we got that idea.

Posted

Sorry, I'm a bit confused. Paragraph A seems to indicate an increasing series number across all packages filled. Paragraph B states that an additional identifier must be present on cases containing bottles, but clearly requires that these identifiers be distinct from those in paragraph A. The way I read it, you must mark each case with two serial numbers, which must be distinct from each other. How can we have distinction if there is only one series?

Additionally, I am wondering about the wording of all the paragraphs. What we are required to do begins with 'must', but many of these sentences include 'may', such as " except that any series of such numbers already in use may be continued to that limit ", which indicates that continuing the series, rather than starting over at 1, is optional?

Has any TTB officer given their specific interpretation of this section of the CFR?

Posted

Sections A and B refer to packaged and bottled product, respectively. You would not have cases 1 through 10, then cask 11.

That 'may' might also be what we had read as allowing A: 1-10 and B: 1-1, now that you mention it.

Posted

We never got direct feedback from TTB on paragraphs (b) and (c). It was unclear to us too if (c) meant you can have different prefixes each running separately from 1 to 1,000,000. But we noted if this were allowed, it looked like we would have to get written notice from a TTB officer. Instead, we label cases with a serial number that includes dash-separated prefixes, and then the running number across all from 1 to 1,000,000, because we felt sure this would satisfy any interpretation, since we could simply state the number portion was the official serial number. But it was good for us as well, finding it better to have a unique number for every case, in case the prefixes are garbled. And when we were inspected, the TTB field agents saw our numbering, and said it was OK, although we did not query on alternatives.

  • 2 weeks later...
Posted

thanks for responses.  It seems like 1-1,000,000 with a prefix for the respective brand/bottling etc would be the appropriate choice.  The alternative interpretations seem likely to lead to confusion. 

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