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Distilling permit

Gray Wolf

A Posse ad Esse. From Possibility to realization.
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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.
 

MJPassion

Observer
ICMag Donor
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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.
 

PDX Dopesmoker

Active member
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-i...c=true&node=pt27.1.22&rgn=div5#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.
 

dybert

Active member
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-i...c=true&node=pt27.1.22&rgn=div5#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.
 

Old Gold

Active member
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
 

Gray Wolf

A Posse ad Esse. From Possibility to realization.
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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

We kept 200 proof ethanol in the corporate lab, but had to keep a log of how we used it or pay taxes.
 

PDX Dopesmoker

Active member
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_drawback_alcohol.shtml
 

dybert

Active member
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.
 

Old Gold

Active member
I don't see many people submitting their recipes, and mailing controlled substances across the country to get them approved.

Just sayin.

Nobody said anything about mailing dabs to feds.
If you're buying ethanol as a business doing licensed extractions, then first of all, your information is pretty public. A quick investigation would tell them that you are a cannabis processor in your state. Now remember, this TTB doesn't recognize cannabis as legal...

If you go look at the application,
(https://www.ttb.gov/forms/f515022.pdf), they do require you fill out:
1) "Purpose for which spirits will be used;"
2) "Purpose for which this application is filed;"
3) "List of equipment used in recovery process (include serial number, kind, capacity, name and address of manufacturer and owner of distilling apparatus, and state the intended use."

You sure could lie about all of it, but that probably isn't the smartest move for a recreational cannabis extraction company. That's all I'm saying...
 
710 Spirits offers 200 proof ethanol, Tax free by adding heptane as a denaturing agent. It's been approved in a few states for extraction.
 
Last edited:

PDX Dopesmoker

Active member
Nobody said anything about mailing dabs to feds.
If you're buying ethanol as a business doing licensed extractions, then first of all, your information is pretty public. A quick investigation would tell them that you are a cannabis processor in your state. Now remember, this TTB doesn't recognize cannabis as legal...

If you go look at the application,
(https://www.ttb.gov/forms/f515022.pdf), they do require you fill out:
1) "Purpose for which spirits will be used;"
2) "Purpose for which this application is filed;"
3) "List of equipment used in recovery process (include serial number, kind, capacity, name and address of manufacturer and owner of distilling apparatus, and state the intended use."

You sure could lie about all of it, but that probably isn't the smartest move for a recreational cannabis extraction company. That's all I'm saying...

That part about TTB not recognizing cannabis as legal shouldn't include the federally legal industrial hemp industry, but it might in the case of extraction uses because hemp extracts containing CBD are schedule 1, however the federal government so far has not prosecuted anyone selling industrial hemp based medicines
 

dybert

Active member
Nobody said anything about mailing dabs to feds.
If you're buying ethanol as a business doing licensed extractions, then first of all, your information is pretty public. A quick investigation would tell them that you are a cannabis processor in your state. Now remember, this TTB doesn't recognize cannabis as legal...

If you go look at the application,
(https://www.ttb.gov/forms/f515022.pdf), they do require you fill out:
1) "Purpose for which spirits will be used;"
2) "Purpose for which this application is filed;"
3) "List of equipment used in recovery process (include serial number, kind, capacity, name and address of manufacturer and owner of distilling apparatus, and state the intended use."

You sure could lie about all of it, but that probably isn't the smartest move for a recreational cannabis extraction company. That's all I'm saying...


I get it... the site SPECIFICALLY says you have to mail them a 2 oz sample. Not feasible for any of us in the legal industry.

" submit a composition of the product and 2 ounce sample of the finished product to:

Alcohol and Tobacco Tax and Trade Bureau
Nonbeverage Products Laboratory
6000 Ammendale Road
Beltsville, MD 20705-1250"
 

WaterFarmFan

Active member
Veteran
Specification-710-Spirits-for-Web-1.jpg


Is this bad compared to Everclear or 200 proof Extractohol?
 

WaterFarmFan

Active member
Veteran
I think Joe answered it for me. Since I make shatter, which might retain a very tiny bit of solvent, this is not for me, but it could be useful if applying more heat with short path or decarbing for edibles.
 

Old Gold

Active member
I think Joe answered it for me. Since I make shatter, which might retain a very tiny bit of solvent, this is not for me, but it could be useful if applying more heat with short path or decarbing for edibles.

Pretty much my thoughts. I can get 99.5% ethyl alcohol with a drop of denaturing agent that boils around 100°C @ atmosphere if I remember correctly.

What are the accepted denaturing agents in the world of regulated processing? Obviously heptane should be ok. Who sets the regulations? Department of Public Health as per FDA standards?
 

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