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TTB regulations are stiff for the most part, but if you are a careful student, you can find some regulatory “freebies” that can save you significant amounts of time and money. Here, we’ll cover three of the most important ones.
1) You Don’t Have to Take Physical Inventory of Barrels
This one’s a bit tricky because you must know TTB’s definition of a “package”:
With this definition in mind, we can steer the ship towards 27 CFR 19.133 – Physical Inventories (of the Storage account):
A proprietor must take a physical inventory of all spirits and wines held in the storage account in tanks and other containers (except packages) at the close of each calendar quarter. A proprietor must record the results of the inventory as provided in subpart V of this part. TTB may require additional inventories at any time.
This means that you can exclude barrels from your physical inventory-taking process! Arguably, you can take it a step further and exclude 55gal metal drums, or even plastic (HDPE) drums!
One important caveat here is that packages (barrels, drums, etc) in the Processing account do not enjoy this exception. If you have any packages in Processing, they must be inventoried twice a year, at the same time as your Finished/Cased Goods are inventoried. See 27 CFR 19.372:
Generally, a proprietor must take physical inventories of bottled and packaged spirits in the processing account for the return periods ending June 30 and December 31, and at any other time that the appropriate TTB officer requires.
2) You Can Ignore the Effect of Obscuration at Low Levels
This one’s a bit more nuanced. TTB considers spirit to be “obscured” if it has dissolved solids in it. They use this term because the presence of solids “obscures” the true proof, if you measure it using the approved standard methods (e.g. Hydrometer/Thermometer or Density Meter).
For example, if you add 2.5 grams of sugar to 1L of 90 proof neutral spirit, the product will test out at 89 proof instead of 90 proof. That extra proof degree of alcohol content was “obscured” by the presence of the solids. This effect is present because we measure the density of spirit in order to determine it’s alcoholic strength, and adding dissolved solids increases the density of the spirit. Since spirit is less dense than water, this increased density reveals itself as a lower proof when measured.
So what’s the freebie? 27 CFR 30.31 contains some instructions for determining the proof of spirits that have dissolved solids in them:
(b) […] the proof of spirits containing not more than 600 milligrams of solids per 100 milliliters of spirits shall be determined by the use of a hydrometer and thermometer in accordance with the provisions of § 30.23 except that if such spirits contain solids in excess of 400 milligrams but not in excess of 600 milligrams per 100 milliliters at gauge proof, there shall be added to the proof so determined the obscuration determined as prescribed in § 30.32.
Parse this regulation carefully and you will see that you shall (must) determine the proof of spirits with solids up to 400mg/100ml using the standard hydrometer/thermometer method (or an equivalent density meter). In other words, you can ignore the effect of solids on your proof measurement, up to 4g / Liter of solids. This allowance covers small amounts of solids like those contributed by the barrel aging process. However, you should know that extended and/or accelerated aging processes can easily cross the 4g/L threshold and require special proofing procedures. The addition of sugar, honey, syrups or just about any other material to spirit will generally cause dissolved solids to accrue in the spirit, and it’s very easy to cross the (relatively low) 4g/Liter threshold.
The allowance above refers to proofing (determining the alcohol content). There is a separate allowance that applies to bulk spirit gauging by weight. If you are determining the volume of your bulk spirit by weighing it, and that spirit has dissolved solids in it, you can ignore the effect of the dissolved solids up to 600mg / 100ml (or 6g / Liter). Once you exceed this threshold, then you must employ the alternative gauging method specified in 27 CFR 30.41.
3)Tank Summary Records in Storage – Virtual Tanks
Depending on the liquid account (Production, Storage or Processing), TTB has different Tank Recordkeeping requirements. In Production, you don’t explicitly keep a record associated with each Tank. Instead, your Production recordkeeping includes information about which tanks, vessels and stills were deposited into or withdrawn from (27 CFR 19.585).
In Processing, you have the most strict/detailed Tank Recordkeeping requirements. 27 CFR 19.598 covers “Dump/Batch Records” and you’ll see that over 20 datapoints are listed!
The “freebie” comes from the Storage account. This account allows you to summarize all of your barreled spirit into a single “package summary record” identifying the number of barrels and a few other data points (27 CFR 19.591).
Similarly, you are permitted to summarize multiple tanks holding the same kind of spirits distilled above 190 proof (neutral spirit). This can be handy if you receive a large number of IBC Totes full of identical neutral spirit. Instead of maintaining a tank record for each tote, you can summarize those totes into a single record. In your distillery management software, this can be accomplished by the use of a “virtual tank”, whose contents match the sum of the spirits held in totes (27 CFR 19.593).
A final note: when you have spirits distilled under 190 proof in your Storage account, the allowance to use a summary record does not apply. You must maintain a tank record for each tank that stores spirits distilled under 190 proof in Storage.
