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Industry Circular

Number: 89-5

Date: October 12, 1989

Department of the Treasury

Bureau of Alcohol, Tobacco and Firearms

Washington, DC 20226


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Proprietors of Distilled Spirits Plants, Bonded Wine Cellars and Breweries.

Purpose: The purpose of this industry circular is to notify the public of the details concerning the recent decision of the Japanese Ministry of Finance to accept analytical data prepared by ATF-certified laboratories in order expedite entry of U.S. wine and spirits into the Japanese market.

Background: Several years ago, the Japanese Ministry of Health and Welfare indicated its willingness to accept analytical data prepared by ATF-certified laboratories in an effort to facilitate the entry of U.S. wine and spirits into Japan.

The concerns of the Ministry of Health and Welfare were and continue to be focused on:

- for spirits (e.g., liqueurs), the name of any coloring agents used; and,

- for grape and other fruit wine, the sulfur dioxide and sorbic acid content.

The Japanese Ministry of Finance has recently indicated that it, too, is now prepared to accept analytical data determined by ATF-certified laboratories.

While the data sought by the Ministry of Health and Welfare is health-related, the concerns of the Ministry of Finance focus on analyses needed for tariff and tax classification of wines and spirits. (Like the Ministry of Health and Welfare, the Ministry of Finance does not require analysis for beer.)

Analytical Data: There are three analyses of interest to the Ministry of Finance, but not all three are needed for every product. The analyses are:

1 - the determination of alcohol content in terms of percent by volume at 20°C. Any means may be used to determine alcohol content;

2 - the determination, by gas pressure measuring device, of the pressure, due to carbon dioxide gas, in the headspace as determined by a gas pressure measuring instrument when the product is kept at a temperature of 20°C in closed containers;

3 - the determination of extract content in grams of the evaporation residue per 100 cm³ of product at a temperature of 15°C.

The following table identifies, in terms of product name and appropriate Japanese tariff category, the products to which one or more of the above analyses apply. It also specifies which analyses are needed (i.e., 1 - alcohol, 2 - pressure, 3 - extract):



SAKE (22.06)

1 AND (2)


1 AND (2)

BEER (22.03)


WINES (22.04, 22.05, 22.06)

1 AND 2

WHISKIES (22.08)

1 AND (2)


1, (2) AND 3

OTHER LIQUEURS (e.g., 2206.00.222, 2208.90.240)

1 AND 2

Where the tariff category of an alcoholic beverage cannot be clearly identified for liquor tax purposes, exporters may be required to submit data about raw materials and manufacturing process.

Where 2 is shown in parentheses [i.e., (2)], this indicates that some products falling under the referenced tariff category may require gas pressure analysis while others may not. Although the Ministry of Finance does not specifically identify the products requiring this analysis, it is advisable to determine gas pressure whenever the product exhibits effervescent qualities upon visual examination.

The presentation of the analytical data referenced herein is not required as a condition of entry. Occasionally, Customs inspection is limited to label examination and does not involve sampling and analysis; however, if it is decided that analysis is needed and if the analytical data is not included as part of the shipping documents, entry may be delayed pending completion of analysis by Japanese Customs laboratories.

There is no specific form or format required for the presentation of these analyses nor must analyses be signed; however, the name and address of the ATF-certified laboratory which performed the analyses should be clearly identified.

Additional Information and Inquiries: A listing of the laboratories certified by ATF for the analysis of wine and more specific information on Japanese tariff and tax classification and rates is available. Inquiries in this regard and questions concerning this circular should refer to its number and be addressed to:

Chief, Alcohol Import-Export Branch Bureau of Alcohol, Tobacco and Firearms 1200 Pennsylvania Avenue, NW Washington, DC 20226

Stephen Higgins

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