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Does anybody know if TTB requires brewery property to be contiguous unit?

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  • Does anybody know if TTB requires brewery property to be contiguous unit?

    To simplify the question, assume suburban small town shopping center, spaces numbered A through E, east to west. Space A and Space E, non-adjacent & separated by several other businesses, are available. If doable, would use space A for brewhouse/fermentation/conditioning/kegging/small taproom (therefore ADA restrooms, too); would use Space E for grain storage, empty keg storage, possibly refrigerated storage for tax determined, kegged beer prior to transport to distributor. (Space E is 1800 sq ft $6 a foot; Space A is 2230 sq ft @ $15/ft; price differences accurately reflect how "nice" they are, relative to each other)

    I had thought state law required contiguity but it turns out I was wrong. Does TTB?

    I know I need to dive into the regs myself but thought somebody might have already researched this...

  • #2
    If you didn't put any beer in Space E, you don't have to do anything special to store ingredients, empty kegs, etc. there. If you have a taproom in Space A, you're already going to have to have a tax-determined area and a non-tax-determined area in that space... if you put the taproom in Space E, you shouldn't have to do anything really special federally either. But once you start mixing beer (pre/post-tax) between the two areas, that is when you will have to be careful with your floor-plans, etc.

    In my state, if I brewed in Space A but had my taproom in Space E, I am sure the state government would have a lot of questions.

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    • #3
      Check with Avery. They're everywhere in that industrial mall out in Boulder, with businesses in between the brewery and bottling area, etc.

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      • #4
        Originally posted by AnthonyB View Post
        If you didn't put any beer in Space E, you don't have to do anything special to store ingredients, empty kegs, etc. there. If you have a taproom in Space A, you're already going to have to have a tax-determined area and a non-tax-determined area in that space... if you put the taproom in Space E, you shouldn't have to do anything really special federally either. But once you start mixing beer (pre/post-tax) between the two areas, that is when you will have to be careful with your floor-plans, etc.

        In my state, if I brewed in Space A but had my taproom in Space E, I am sure the state government would have a lot of questions.
        Agreed. Tap room would be in space A. I oversimplified; Space E is actually an existing storage space, but with electricity, around back, but not contiguous to Space A. I wanted to maybe lager and barrel age in Space E. Or maybe, just hold packaged beer there (in addition to raw materials and packaging materials) pending delivery to/pickup by distributor (no self distribution in state in question). Could I have tax-determined and non-tax-determined areas in both spaces?

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        • #5
          Originally posted by rudge75 View Post
          Check with Avery. They're everywhere in that industrial mall out in Boulder, with businesses in between the brewery and bottling area, etc.
          I was actually thinking about Avery when I posted; but I did think that each of their expansions over the years was into contiguous space. Thinking about it, I was probably wrong. I know some folks out there, I'll see if I can pick somebody's brain. Thanks for the tip!

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