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Old 01-26-2018, 10:03 AM #1
einsteinlady
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Distilling permit

Anyone that uses ethanol for extraction/recovery; have you gotten a federal permit to reclaim the ethanol?
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Old 01-26-2018, 12:07 PM #2
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A distillers license requires a facility equipped to meet the fire codes and occupancy requirements, so excludes residences. Some wiggle room for stills under a gallon and used in labs.
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Old 01-26-2018, 02:21 PM #3
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Waiting for me some Old Number 7 extract!

Shit... the alcohol lobby should embrace this before the pharmaceutical companies take all of the market share.
Jus kidding y’all.
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Old 01-27-2018, 01:49 AM #4
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Quote:
Originally Posted by einsteinlady View Post
Anyone that uses ethanol for extraction/recovery; have you gotten a federal permit to reclaim the ethanol?
I don't think that people who are using ethanol as an industrial solvent are subject to TTB regulations and fees, those regulation are for the alcoholic beverage industry only. Any permitted legal use of ethanol in cannabis extraction (i.e. at a federally legal hemp farm) should be permitted under the PART 22—DISTRIBUTION AND USE OF TAX-FREE ALCOHOL rules ( https://www.ecfr.gov/cgi-bin/text-id...se27.1.22_1101 )
Furthermore, evaporating high proof alcohol and recovering similarly high proof alcohol isn't distillation with respect to the licensing requirements because the net increase in alcohol percentage is negligible. It would probably be a storage permit rather than a distillation one.

If the question question were rephrased as "have you gotten a federal permit to store ethanol?" then my answer would be no, because I don't reclaim my alcohol most of the time, I'm a filthy polluter. I don't want a bunch of suspicious looking equipment in my house making it look like its a drug lab. Mother nature will reclaim it for me.
Anyway don't get stuck into paying alcohol excise tax for your industrial solvents if you don't need to. Most of us are accustomed to getting our solvent alcohol via the alcoholic beverage industry by going to the liquor store, but there is a less expensive way if the alcohol isn't intended for ingestion.
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Old 01-27-2018, 06:01 PM #5
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Quote:
Originally Posted by PDX Dopesmoker View Post
I don't think that people who are using ethanol as an industrial solvent are subject to TTB regulations and fees, those regulation are for the alcoholic beverage industry only. Any permitted legal use of ethanol in cannabis extraction (i.e. at a federally legal hemp farm) should be permitted under the PART 22—DISTRIBUTION AND USE OF TAX-FREE ALCOHOL rules ( https://www.ecfr.gov/cgi-bin/text-id...se27.1.22_1101 )
Furthermore, evaporating high proof alcohol and recovering similarly high proof alcohol isn't distillation with respect to the licensing requirements because the net increase in alcohol percentage is negligible. It would probably be a storage permit rather than a distillation one.

If the question question were rephrased as "have you gotten a federal permit to store ethanol?" then my answer would be no, because I don't reclaim my alcohol most of the time, I'm a filthy polluter. I don't want a bunch of suspicious looking equipment in my house making it look like its a drug lab. Mother nature will reclaim it for me.
Anyway don't get stuck into paying alcohol excise tax for your industrial solvents if you don't need to. Most of us are accustomed to getting our solvent alcohol via the alcoholic beverage industry by going to the liquor store, but there is a less expensive way if the alcohol isn't intended for ingestion.
Unless all of your recipes are documented and approved by the DEA you are paying drinking tax on ethanol.

I don't know of anyone in the industry (I've been extracting professionally for 10 years) that has actually submitted to the DEA for a tax exempt status.
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Old 01-27-2018, 07:14 PM #6
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As per Alcohol & Tobacco Tax & Trade Bureau at the U.S. Department of the Treasury:

"Tax-Free alcohol may not be withdrawn and used
for beverage purposes, or in any food product, or
in any preparation used in preparing a beverage
or a food product."

"Tax-Free alcohol may not be used in the
manufacture of any product which will be sold or in
any product resulting from the use of tax-free
alcohol which will be sold. Hospitals, sanitariums,
or clinics may, however, make a separate charge
for medicines compounded on the premises and
dispensed to patients for use on the premises."


So basically, if the ethanol makes a product that is to be sold, or if that product is meant for ingestion, the alcohol doesn't qualify as tax-exempt. I doubt that smoking the product will be a loophole in the eyes of TTB. The link below also includes information regarding "Production and Use of Distilled Spirits for Experimental Research."

https://www.ttb.gov/industrial/taxfree_regs_laws.shtml
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Old 01-27-2018, 10:20 PM #7
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Quote:
Originally Posted by Old Gold View Post
As per Alcohol & Tobacco Tax & Trade Bureau at the U.S. Department of the Treasury:

"Tax-Free alcohol may not be withdrawn and used
for beverage purposes, or in any food product, or
in any preparation used in preparing a beverage
or a food product."

"Tax-Free alcohol may not be used in the
manufacture of any product which will be sold or in
any product resulting from the use of tax-free
alcohol which will be sold. Hospitals, sanitariums,
or clinics may, however, make a separate charge
for medicines compounded on the premises and
dispensed to patients for use on the premises."


So basically, if the ethanol makes a product that is to be sold, or if that product is meant for ingestion, the alcohol doesn't qualify as tax-exempt. I doubt that smoking the product will be a loophole in the eyes of TTB. The link below also includes information regarding "Production and Use of Distilled Spirits for Experimental Research."

https://www.ttb.gov/industrial/taxfree_regs_laws.shtml
We kept 200 proof ethanol in the corporate lab, but had to keep a log of how we used it or pay taxes.
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An age is called Dark not because the light fails to shine, but because people refuse to see it.

Believing is seeing and ignorance is bliss until it bites you in the ass!

Fervor is the weapon of the impotent. The harder the sell, the poorer the product.

Alas, my ignorance abounds; the more I've learned, the less I know that I know..........

Thou shalt seek and respect the opinions of operators, even unto the third helper, for theirs is a wisdom unknown to technicrats.

Wise men learn more from fools, than fools from wise men.

In my dotage I finally discovered that the secret to putting on pants both legs at a time is sitting down.
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Old 01-28-2018, 02:51 AM #8
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Quote:
Originally Posted by Old Gold View Post
As per Alcohol & Tobacco Tax & Trade Bureau at the U.S. Department of the Treasury:

"Tax-Free alcohol may not be withdrawn and used
for beverage purposes, or in any food product, or
in any preparation used in preparing a beverage
or a food product."

"Tax-Free alcohol may not be used in the
manufacture of any product which will be sold or in
any product resulting from the use of tax-free
alcohol which will be sold. Hospitals, sanitariums,
or clinics may, however, make a separate charge
for medicines compounded on the premises and
dispensed to patients for use on the premises."


So basically, if the ethanol makes a product that is to be sold, or if that product is meant for ingestion, the alcohol doesn't qualify as tax-exempt. I doubt that smoking the product will be a loophole in the eyes of TTB. The link below also includes information regarding "Production and Use of Distilled Spirits for Experimental Research."

https://www.ttb.gov/industrial/taxfree_regs_laws.shtml
They have loopholes for that, flavor extract manufacturers get a 93% refund on alcohol excise taxes. https://www.ttb.gov/ssd/nonbeverage_..._alcohol.shtml
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Old 01-28-2018, 05:47 AM #9
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Quote:
Originally Posted by PDX Dopesmoker View Post
They have loopholes for that, flavor extract manufacturers get a 93% refund on alcohol excise taxes. https://www.ttb.gov/ssd/nonbeverage_..._alcohol.shtml
Not a loophole at all, very legitimate! Thanks for this
I still think food products would not qualify for the refund. Smokeables maybe.... (still doubtful)

Last edited by Old Gold; 01-29-2018 at 07:06 PM..
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Old 01-29-2018, 12:07 AM #10
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Quote:
Originally Posted by Old Gold View Post
Not a loophole at all, very legitimate! Thanks for this
I still think food products would not qualify for the refund. Smokeables maybe....
I don't see many people submitting their recipes, and mailing controlled substances across the country to get them approved.

Just sayin.
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