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Industry Circular

Number: 78-2

Date: March 20, 1978

Department of the Treasury

Internal Revenue Service

Alcohol, Tobacco, and Firearms Division

Washington, D.C. 20224



Proprietors of Distilled Spirits Plants and Others Concerned:

Purpose. This circular is issued to inform proprietors of distilled spirits plants that an ATF ruling pertaining to the sealing of conveyances used to transport spirits will be published in the March issue of the Alcohol, Tobacco and Firearms Bulletin. The ruling will read substantially as follows:

Treasury Decision ATF-46 instituted changes in the distilled spirits plant regulations prescribed in title 27, Code of Federal Regulations, part 201. One of the changes requires proprietors to seal conveyances of distilled spirits with their own seals rather than rely upon ATF officers to secure the conveyances with Government seals.

While seals affixed to outlet valves and manheads have to be broken to effect the routine removal or loading of spirits, there normally is no need to break seals which secure hinge pins, valves, air vents, baffle plates, etc. Therefore, in consideration of the materials and manpower which would have to be expended to remove and replace all seals each time a conveyance is put into use by a different proprietor, it is held that those seals on a bulk conveyance which remain intact from one shipment of distilled spirits to another may be used repeatedly by the same or by dif- ferent proprietors, provided the shipping document, e.g., ATF F 236, Transfer of Spirits or Denatured Spirits in Bond, is marked with the serial number and unique identi- fier of each intact seal previously affixed to the conveyance as well as that of any seal affixed for the current shipment.

Inquiries. Inquiries concerning this circular should refer to its number and be addressed to the Assistant Director (Regulatory Enforcement), Bureau of Alcohol, Tobacco and Firearms, 1200 Pennsylvania Avenue, NW., Washington, DC 20226.

Rex Davis


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