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Transfer in bond to Winery


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We have a local winery that wants to partner and collaborate on a product line. They're wanting to bring in bulk spirits from our DSP and fortify soda that they make and can it as a canned cocktail.

The main question: is it even possible to transfer bulk spirits besides grape based brandy/neutral to a winery?

Thank you in advanced!

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Off the top of my head I'm going with no. Wineries can only typically use grapes, fruit, honey, cane sugar, grape brandy, fruit brandy, grape concentrate, et al so something like GNS or whiskey would not be allowed. And anyway, a soda cocktail product made with some random alcohol cannot be done by a winery as far as I know. They need to investigate that idea a little more I think.

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This is an issue I have had a problem with.

Currently, local winery buys GNS and mixes down, adds to wine and calls it sherry.  I don't understand how they do it.

I think the distillery could transfer in wine from distillery in bond,  distill it, proof and transfer back to winery.

I think you could bring in their wine, make the beverage and return it to them for canning.

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My understanding is that wineries can only use spirit from the same fruit type as the beverage being fortified. As they are not allowed to brew beer, they can't use grain neutral to fortify anything. If their license lets them make fermented cane sugar soda (which I understand it does) they could use cane neutral? Should probably ask the ttb agent. 

FallIng Rock, perhpas the GNS is grape neutral spirit? 


"The proprietor of a bonded wine premises may withdraw and receive spirits without payment of tax from the bonded premises of a distilled spirits plant for uses as are authorized in this part. Wine spirits produced in the United States may be added to natural wine on bonded wine premises if both the wine and the spirits are produced from the same kind of fruit. In the case of natural still wine or natural still hard cider, wine spirits may be added in any State only to wine produced by fermentation on bonded wine premises located within the same State. If wine has been ameliorated, wine spirits may be added (whether or not wine spirits were previously added) only if the wine contains not more than 14 percent of alcohol by volume derived from fermentation. Spirits other than wine spirits may be received, stored and used on bonded wine premises only for the production of nonbeverage wine and nonbeverage wine products. Wooden storage tanks used for the addition of spirits may be used for the baking of wine."


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  • 1 month later...

This too slipped by my notice.  I write largely in confirmation, but cite the sources, to show how to reach the conclusions others have made.

1/  A winery cannot make canned cocktails.  They are distilled spirits products.

  • See 5.35(b)(1), so they must be made and packaged on DSP premises
  • Sec. 19.71   Except as otherwise provided in this part, a person may only conduct operations as a distiller, warehouseman, or processor of distilled spirits on the bonded premises of a distilled spirits plant.).  

That is basic.  If the DSP combines the wine and spirits, it has made a distilled spirits product.  The DSP could not rectify the product and remove it to the winery for canning.  That would violate the bulk sales provisions of the FAA Act (27 CFR.180).  

2/  A winery can receive and use wine spirits in the manufacture of wine products.  

  • 19.10 - Wine spirits. Brandy or wine spirits authorized under 26 U.S.C. 5373 for use in wine production.
  • Sec. 5373 (a) The wine spirits authorized to be used in wine production shall be brandy or wine spirits produced in a distilled spirits plant (with or without the use of water to facilitate extraction and distillation) exclusively from— (1) fresh or dried fruit, or their residues, (2) the wine or wine residues, therefrom, or (3) special natural wine under such conditions as the Secretary may by regulations prescribe.)

3/ The winery can add wine spirits to wine produced from the same kind of fruit as the spirits. (As cited by Just Andy, above - 24.255 - Wine spirits produced in the United States may be added to natural wine on bonded wine premises if both the wine and the spirits are produced from the same kind of fruit).  )  

4/ Yes, neutral spirits grain and  neutral spirits grape might have the same acronym, so it may be that the winery mentioned above is receiving "neutral grape, not neutral grain spirits.  No DSP should ship grain spirits to any winery.  Both would be in violation.  (Sec. 19.419  Withdrawals of spirits for use in wine production.    A proprietor may withdraw wine spirits without payment of tax for transfer in bond to a bonded wine cellar for use in wine production).

4/  The same fruit requirement allows other than grape spirits. Any spirit produced by materials listed under 5373 is acceptable.  

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  • 2 years later...

You do not use a form.  When a winery ships wines  to you, they do so on a transfer record required by §24.309 and you record the receipt as required by §19.621.  When you ship spirits to a winery, you make the transfer record required by §19.620 and the winery completes it as required by part 24.  See also §§ 19.405, 19.407 and 19.419 for provisions re allowed transfers and the requirements placed on the consignee and consignor.

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