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View Full Version : Does anybody know if TTB requires brewery property to be contiguous unit?



uptown brothers
10-22-2013, 04:46 PM
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...

AnthonyB
10-22-2013, 08:15 PM
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.

rudge75
10-23-2013, 09:18 AM
Check with Avery. They're everywhere in that industrial mall out in Boulder, with businesses in between the brewery and bottling area, etc.

uptown brothers
10-23-2013, 10:35 AM
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?

uptown brothers
10-23-2013, 10:37 AM
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!