Using SDS to Manufacture Articles

Using SDS to Manufacture Articles

Obtain an Industrial Alcohol User Permit (The document issued under 26 U.S.C. 5271(a), authorizing a person to withdraw and deal in or use SDS or to recover SDS, or articles under specified conditions.) (Form 5150.22) in order to manufacture articles.
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- There are three (3) types of proprietors:
  - Manufacturer or User (A person who holds a permit, issued under 27 CFR part 20 to withdraw and use SDS, or to recover CDA or SDS, or articles manufactured with SDS, or a proprietor of a DSP qualified under 27 CFR part 19 as a processor.)
  - Distilled Spirits Plant (DSP) (An establishment which is qualified under 27 CFR part 19 to conduct distilled spirits operations, including processing specially denatured spirits or manufacturing articles. Also referred to as a denaturer or processor.)
  - Dealer (A person who purchases and stores SDS for resale to users of SDS or to other dealers. A dealer conducts no manufacturing or processing operations but may package SDS in appropriate size containers for resale. This term does not include a person who only buys and sells SDS and never physically receives or intends to receive SDS.)
- Permits are issued through the application services function of the National Revenue Center.
- This can be done prior to or concurrently with applying for formula approval
Choose the appropriate formula in 27 CFR parts 20 and 21.
- There are three (3) options:
  - General-use formula (Any of approved articles made in accordance with Subpart F of 27 CFR part 20. These articles do not require formula approval on TTB Form 5150.19 and the customer does not need a permit to purchase an article made in accordance with a general-use formula. However, the manufacturer needs a permit to manufacture a general-use formula.)
  - SDA (Alcohol which has been treated with denaturants to make it unfit for beverage use pursuant to the specially denatured alcohol formulas authorized under subpart D of 27 CFR part 21. Also referred to as specially denatured spirits (SDS).)/SDR (Rum denatured to make it unfit for beverage use pursuant to the one specially denatured rum formula authorized under subpart D of 27 CFR part 21.) formula
  - CDA (The spirits known as alcohol denatured pursuant to completely denatured alcohol formulas prescribed in subpart C of 27 CFR part 21 and on the TTB website at http://www.ttb.gov/ industrial/cda_rulings.shtml. A permit is not needed to purchase completely denatured alcohol.) formula
- When choosing a formula, it must be:
  - Suitable for the intended use;
  - Free of restrictions that would prevent its use in a particular process; and
  - Approved in TTB's regulations.
Apply for and obtain TTB formula approval on TTB Form 5150.19 or in Formulas Online before manufacturing, except when using general-use formulas or CDA.
- Requirements for Approval:
  - The use of additional chemicals and/or essentials oils to ensure that the finished liquid article cannot be reclaimed or diverted to beverage use.
  - The additional chemicals and/or essentials oils cannot be easily separated from the ethanol.
  - Ideally the article should contain a warning odor, color, and/or taste.