Is it ok to have a 2.0 liter whiskey container?

Robert LehrmanRobert Lehrman Posts: 29 admin
edited June 2015 in TTB/Federal Compliance
And, how about a 25 ml. vodka container?

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Answers

  • Alex OxfordAlex Oxford Posts: 42 admin
    edited July 2015
    So the TTB's brochure on spirits is telling me no, but I DID find an approved COLA with 2.0 liters (Cola number 14255001000370) but it was for beer. The smallest ml I saw for spirits was 50ml. So I'm thinking that's a no!
  • Robert LehrmanRobert Lehrman Posts: 29 admin
    OK here's why I asked. I recently saw a retail vodka package larger than 1.75 liters. This was a great surprise because the conventional wisdom, for decades, has been that spirits packages can't be larger than 750 ml., 1 liter, or 1.75 liters. Here's how a smart company pushed the limits. The put two 1.75 liter vessels within one box, like a bag-in-box with two spouts. Extra points for anyone who can find the COLA(s) within LabelVision.
  • Robert LehrmanRobert Lehrman Posts: 29 admin
    And yes it's ok to go smaller than TTB's "minimum" spirits size of 50 ml. But most people know that already. For example, a bunch of 20 ml. packets adding up to 100 ml. Seems like TTB has bigger fish to fry, than trying to tell people how big their container ought to be.
  • Alex OxfordAlex Oxford Posts: 42 admin
    Can we get a clue?
  • RyanSRyanS Posts: 4
    edited July 2015
    ....
  • Robert LehrmanRobert Lehrman Posts: 29 admin
    edited July 2015
    Alex here are some clues to find the surprising >1.75 liter vodka package. It is domestic, vodka, approved within the past year, a box (with the term "box" as part of the labeling). Also, this topic has appeared on Reddit (with a good photo of the box).
  • Robert LehrmanRobert Lehrman Posts: 29 admin
    Yes Ryan you got it. The COLA should not be hard to find, with the power of LabelVision.
  • chirvinchirvin Posts: 2
    And yes it's ok to go smaller than TTB's "minimum" spirits size of 50 ml. But most people know that already. For example, a bunch of 20 ml. packets adding up to 100 ml. Seems like TTB has bigger fish to fry, than trying to tell people how big their container ought to be.
    This still seems pretty suspect to me. As you said Robert, aggregate packaging allows 5 20 mL packages to equal the 100mL standard of fill. Why wouldn't two 1.75s boxed together be considered an aggregate package with the same logic applied to smaller packages?

    If the aggregate packaging logic doesn't apply when going big, is there any reason you couldn't package two different products in the same box? Let's say you have two 1.75s and the box is split with the art of product 1 on one side and the art of product 2 on the opposite side. It seems to me that's the sort of thing TTB wouldn't really allow, but it's not all that different than the Nikolai product shown in the reddit thread.
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