All contract manufacturing - do I need Licenses?

[simpleskiff]

hi all,

so i have a question that may be naive. If i started a "brewery", but everything is contracted out - from the manufacturing, to the warehousing/storage, and then the beer is picked up directly by the distributor, do I need TTB and state licenses? aka if I don't ever touch it, do I need a license?

The hope would be to start producing and selling now while i wait for license approval, but seeing as that can take up to a year, it would be great to get going now since I plan to contract everything out anyways. Thoughts?

 

[specharka]

Sounds like something you should consult a lawyer for.

But more importantly, why would you risk it? The penalties for unauthorized distribution and sale of alcohol are severe and financially crippling. Seems like a poor decision for an aspiring entrepreneur.

 

[eastoak]

I know a contract brewer and they will even get your beer into BevMo as part of the deal. If you will be a business you would need all of that legal stuff (business license and so on) done but nothing to do with brewing since you’re actually brewing.

 

[SanPancho]

You need whats called alternating premises/proprietor. I believe you still need a brewers notice from ttb. But possibly not a state license since you don’t actually ferment.

In general, id say its not a good idea. Lots of potential negatives, not many positives in my opinion.

Lehman beverage law can advise you more. For a fee.

 

[eastoak]

https://www.craftbrewingbusiness.co...wing-regulatory-licensing-tax-considerations/