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Industry Circular

Number: 76-28

Date: December 6, 1976

Department of the Treasury

Bureau of Alcohol, Tobacco and Firearms

Washington, DC 20226



Proprietors of Distilled Spirits Plants and Others Concerned:

Purpose. The purpose of this circular is to announce that the Director will consider applications from distilled spirits plant proprietors for permission to conduct, for experimental purposes, operations involving the manufacture of new barrels with used heads and the use of such barrels in the aging of bourbon whiskey.

Background. The Bureau has been asked to consider the possibility of authorizing the reuse of heads taken from used barrels in the production of "new charred" barrels. The face of such a used barrel head would be charred and reversed so that, when assembled as a package with new charred staves, the newly charred face would be in contact with the whisky. The previously charred surface of such a head would be shaved and prepared so that the mandatory marks and brands required by 27 CFR 201.516 could be affixed.

Since whisky derives much of its character from the type of wood in which it is stored, ATF standards of identity require that certain whisky--i.e., bourbon--be stored in new charred oak cooperage. Traditionally, we have required such containers to be made entirely from new oak wood which has been charred for the first time.

Although we are aware that industry members could reduce costs by using recharred heads from used packages in producing new charred oak packages, we are uncertain what, if any, effect our permitting this practice would have on whisky stored in such packages. Therefore, in order to gain the information needed to issue a formal position on this matter, we are author- izing interested distilled spirits plant proprietors to conduct experimental programs involving the use of recharred, reused heads in packages used for storing bourbon whiskey.

Applications. A proprietor of distilled spirits plants who wishes to participate in the experimental program must adhere to the following conditions:

1. At least 25 barrels with conventional heads shall be filled, for control purposes, with the same whisky being filled into the experimental barrels from the first five lots produced under this authorization. The producer shall subsequently fill such other conventional barrels for control purposes as he deems necessary.

2. Control barrels shall be stored in essentially the same locations and under the same conditions as the experimental barrels.

3. Two years after the filling of experimental barrels has commenced, the assigned officer shall take one half-pint sample from each of five of the oldest experimental barrels and five corresponding control barrels. Such samples will be submitted to the ATF Headquarters Laboratory for testing and analysis.

4. At least 6 months prior to removing such whisky for bottling, one half-pint sample shall be taken from each of 15 of the experimental barrels to be withdrawn and from 15 control barrels with corresponding fill dates. Such samples will be selected and taken by an ATF officer for analysis and testing by the ATF Headquarters Laboratory.

5. All barrels filled for the purposes of this experiment shall be clearly identified by a coding which will distin- guish them from whisky that is not part of the experiment, and will distinguish control barrels from the experimental barrels in each lot.

6. The records pertaining to all control and experimental barrels filled under this authorization shall be maintained separately.

7. Whisky filled into experimental barrels shall not sub- sequently be mingled with whisky filled into conventional barrels without first obtaining the approval of this office. For this purpose, samples of such whisky, along with samples from control barrels having corresponding fill dates, will be submitted in the manner set forth in number three above. Under the terms of this approval, such whisky, if otherwise eligible, may be withdrawn, bottled and labeled as straight bourbon whiskey.

An application to participate in the above-described experi- mental program should be furnished to the regional regulatory administrator of the applicant's region. A proprietor may not commence experimental operations described in this circular before receiving approval of his application,

Inquiries. Inquiries regarding this circular should refer to its number and be addressed to the Director, Bureau of Alcohol, Tobacco and Firearms, 1200 Pennsylvania Avenue, NW, Washington, DC 20226, Attention: R:I:R.

Rex Davis

Rex D. Davis


GPO 911-331

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