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Requirements for bottling an alcoholic drink


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#1 solrac

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Posted 17 April 2019 - 01:10 PM

Hi.

 

We are currently a custom blending company. My question is can we bottle an alcoholic drink e.g. bitter tincture? Based on my readings, co-packing alcoholic drink is a different ball game. Is there someone here can give me some thoughts? Thank you.



#2 pHruit

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Posted 17 April 2019 - 01:32 PM

Hi.

 

We are currently a custom blending company. My question is can we bottle an alcoholic drink e.g. bitter tincture? Based on my readings, co-packing alcoholic drink is a different ball game. Is there someone here can give me some thoughts? Thank you.

What are you currently custom blending, as in, what is your point of reference/comparison for alcoholic drinks being a different ballgame?

In general they're more microbiologically robust than many soft drinks, but there can be other challenges.

Will you be developing and producing the product, or simply bottling an existing recipe for the customer using their ingredients?



#3 solrac

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Posted 17 April 2019 - 01:50 PM

Hi. Blending of dry ingredients to be specific. We will just be bottling an existing recipe. Thank you.



#4 pHruit

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Posted 17 April 2019 - 02:09 PM

OK, that's quite a significant change of product type then!
With bitters you'll probably have an ABV that makes life easy in terms of microbiological concerns.

Some types of spirits will go through a cold filtration stage as part of processing, to reduce/prevent flocculation. Hopefully this will have already been considered as part of the brand owner's recipe/process development.
If you're using water in the recipe then this can sometimes create a challenge, as different water sources will have different compositional characteristics - changing this can in some cases lead to formation of certain precipitates, development of hazes etc. I've seen quite a few alcoholic drinks producers caught out by this one ;) (To be fair it can also affect soft drinks producers too, and they're equally indifferent to it until it hits their product...).

 

If the customer is supplying what is effectively a finished blended product that you need to literally just put into bottles then your life should theoretically be fairly simple. Nonetheless, I'd ask them to define exactly what process they're expecting you to undertake, so you can review and confirm that you really can do what is expected of you. (I've seen a few "oh, we'd assumed that you'd know you were supposed to do x to it" incidents with brand owners / contract packers over the years),

If you're being given a set of component parts and are expected to assemble the recipe, particularly if using your own potable water source(s), then I'd strongly recommend trialling it in the lab first, and again I'd be asking exactly what process the client is expecting of you.

It could turn out to be a product that requires no special processing etc., but best to be absolutely sure of such things beforehand.

 

Obviously you'll also need to do the usual food safety bits in terms HACCP / HARPC or whatever is applicable in the US and/or required for your certification, possibly check whether your customer wants you to add this to your certification scope etc, and also look at glass/brittle materials control if you're not already using glass (I'm assuming you'll be packing into glass bottles) on site.

 

N.B. I have no idea how the duty/tax system works for alcohol production in the US, so you may also need to look into that. Over here you'd need to register with HMRC (tax collection authority) to store and/or process this type of product, or have it supplied to you with the duty already paid.



#5 solrac

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Posted 17 April 2019 - 04:55 PM

Thank you pHruit.

 

This is very informative. :-)



#6 Watanka

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Posted 17 April 2019 - 06:43 PM

Solrac,

 

See TTB regulation below, particularly (b) exception for beverage products.  Some bitters do not fall under TTB, but rather go to FDA, likely based upon the determination made by TTB when the formula is submitted for review.  Contact the TTB, tell them what you want to do, explain the ingredients in your formula and they can give you guidance.  

 

27 CFR §19.5   Manufacturing products unfit for beverage use.

(a) General. Except as provided in paragraph (b) of this section, apothecaries, pharmacists, or manufacturers who manufacture or compound any of the following products using tax paid or tax determined distilled spirits are not required to register and qualify as a distilled spirits plant (processor):

(1) Medicines, medicinal preparations, food products, flavors, flavoring extracts, and perfume, conforming to the standards for approval of nonbeverage drawback products found in §§17.131 through 17.137 of this chapter, whether or not drawback is actually claimed on those products. Except as provided in paragraph © of this section, a formula does not need to be submitted if drawback is not desired;

(2) Patented and proprietary medicines that are unfit for use for beverage purposes;

(3) Toilet, medicinal, and antiseptic preparations and solutions that are unfit for use for beverage purposes;

(4) Laboratory reagents, stains, and dyes that are unfit for use for beverage purposes; and

(5) Flavoring extracts, syrups, and concentrates that are unfit for use for beverage purposes.

(b) Exception for beverage products. Products identified in part 17 of this chapter as being fit for beverage use are alcoholic beverages. Bitters, patent medicines, and similar alcoholic preparations that are fit for beverage purposes, although held out as having certain medicinal properties, are also alcoholic beverages. These products are subject to the provisions of this part and must be manufactured on the bonded premises of a distilled spirits plant.

© Submission of formulas and samples. When requested by the appropriate TTB officer or when the manufacturer wishes to ascertain whether a product is unfit for beverage use, the manufacturer will submit the formula and a sample of the product to the appropriate TTB officer for examination. TTB will determine whether the product is unfit for beverage use and whether manufacture of the product is exempt from qualification requirements.

(d) Change of formula. If TTB finds that a product manufactured under paragraph (a) of this section is being used for beverage purposes, or for mixing with beverage spirits other than by a processor, TTB will notify the manufacturer to stop manufacturing the product until the formula is changed to make the product unfit for beverage use and the change is approved by the appropriate TTB officer. However, the provisions of this paragraph will not prohibit products which are unfit for beverage use from use in small quantities for flavoring drinks at the time of serving for immediate consumption.

(26 U.S.C. 5002, 5171)



#7 solrac

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Posted 17 April 2019 - 08:00 PM

Thank you Watanka!



#8 lengland

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Posted 18 April 2019 - 07:28 PM

You can check the Bureau of Alcohol, Tobacco, Firearms, and Explosives web site to see if there are any requirements.  www.atf.gov

We use specially denatured alcohol in some products and we are required to report our usage to the ATF.



#9 Tatau

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Posted 19 April 2019 - 03:21 AM

Thank you Watanka. This helped me.



#10 SunilDogra

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Posted 22 April 2019 - 04:54 AM

Thanks for this informative thread. I had gained much knowledge while reading this.


Edited by SunilDogra, 22 April 2019 - 04:54 AM.





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