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Both DISTILL x 5 and Whiskey Systems offer you the ability to generate Case Labels for your bottled, finished goods, which helps you to meet your CFR requirements for case marking:
But this is just the beginning of regulations around cased goods.
You are also required to fill cases with properly filled & closed bottles. Each case may contain only one “kind” and proof of spirits, for example “Bourbon Whiskey at 100 Proof” or “Vodka at 80 Proof”.
Once you have filled, marked, and sealed your case of bottles, it may be stored in bonded premises indefinitely.
Cases stored in bond should remain sealed until removal from bond in whole case increments. Breaking the seal of a case in bonded premises and then removing one or more bottles is not permitted. I see distilleries violating this provision regularly: they break cases in bond to get sample bottles, sales samples, tasting room stock and more. This isn’t actually allowed! If you need one bottle of Vodka and all you have is a 12pk sealed case in bond, then guess what: you’re removing the entire 12pk from bond, paying the Federal Excise Tax on the whole case, and only then can you break the case and pull your bottle.
I see this all the time: if you have loose bottles in your bonded area, it’s potentially a red flag!
There’s more. Let’s say that you’re bottling Vodka into 12pk cases. And let’s say that at the end of the bottling day, you have 9 bottles left over. You can’t fill & seal a case, but you also can’t have loose bottles sitting around unidentified. Luckily, the regulations have considered just this situation.
You simply take the last case serial that you applied to the last full case and duplicate it. Apply this case marking to the partial 9-bottle case, and then write an “R” on it for “Remnant”. This “Remnant” case may be held in bond until the next time you bottle that same product, at which point you’ll be able to complete the case and apply the proper case serial. You can also use remnant bottles to replace accidental breakage in bond. What you cannot do is remove those “loose” or “extra” remnant bottles from bond. At the risk of sounding like a broken record: you can only remove bottles from bond in sealed, whole case increments.
Some proprietors wonder, “Surely there must be a way to get single bottles out of bond?”
My answer is: “In a case”. Regulations are silent about what constitutes a “case”, and there isn’t a minimum number of bottles specified. By my reading, it appears that a “1-bottle Case” is technically permissible, although it would still require the same markings as a full case.
These regulations illustrate why it’s handy to have a section of your DSP marked off as “General Premises” (also known as Tax Paid Premises). You can ‘remove’ cases out of Bond and place them in General Premises, where case regulations no longer apply. Once in General Premises, you can repack the product into a mixed pack, break off single bottles for samples and more. See my blog post on Bonded Premises for more on this.
