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Using SDS to Manufacture Articles

Using SDS to Manufacture Articles

  • Obtain an Industrial Alcohol User Permit (Form 5150.22) in order to manufacture articles.

    • There are three (3) types of proprietors:

      • Manufacturer or User
      • Distilled Spirits Plant (DSP)
      • Dealer

    • 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
      • SDA/SDR formula
      • CDA 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.

Last updated: December 7, 2018