Distillers, Rectifiers, Processors, Non Distillery Producers (NDPs), and Spirit Architects  (Oh My !)

Types and Definitions
(1) Distiller 
The term “distiller” includes any person who:
(A) produces distilled spirits from any source or substance,
(B) brews or makes mash, wort or wash fit for distillation or for the production of distilled spirits, other than the making or using of mash, wort or wash in the authorized production of wine or beer, or the production of vinegar by fermentation,
(C) by any process that separates alcoholic spirits from any fermented substance, or
(D) making or keeping mash, wort, or wash, has a still in his possession or use.
(2) Non Distillery Processor or Producer 
(A) In general 

The term “processor”, when used with respect to distilled spirits, means any person who:
(i) manufactures, mixes, or otherwise processes distilled spirits, or
(ii) manufactures any article.
(B) Rectifier, bottler, etc., included 

The term “processor” includes (but is not limited to) a rectifier, bottler, and denaturer.
(3) Certain operations not treated as processing 
In applying paragraph (2), there shall not be taken into account—
(A) Operations as distiller 

Any process which is the operation of a distiller.
(B) Mixing of taxpaid spirits for immediate consumption 

Any mixing (after determination of tax) of distilled spirits for immediate consumption.
(C) Use by apothecaries 

Any process performed by an apothecary with respect to distilled spirits which such apothecary uses exclusively in the preparation or making up of medicines unfit for use for beverage purposes.
So What is Rectification and who is a Rectifier?
Rectification is any process or procedure whereby distilled spirits are cut, blended, mixed or infused with any ingredient which reacts with the constituents of the distilled spirits and changes the character and nature or standards of identity of the distilled spirits.
One example of rectification is, but not necessarily limited to, creating products such as “lemoncello” or “limoncello” in which sugar and citrus products are combined with vodka and stored, initiating a maturation process which consequently changes the character and nature of the vodka, and possibly its alcohol content.This processing can be in the form of infusion, maceration, compounding, etc., etc.,
Another is taking a spirit and re-barreling it in say, a rum cask and aging, adding wood chips, or simply re-barreling and re-aging for a longer period.
The simple mixing of alcoholic beverages with other ingredients for immediate consumption (read cocktails and similar drinks) is not considered rectification.
This is a technical definition of rectification.
In general use in the industry it is also understood to also mean someone who takes bulk neutral spirits and redistills (or tweaks)  them to change their character – usually attempting different cuts to clean or distill them to an even more neutral form, or someone who buys a bulk spirit and makes a minor change to call it their own (creation).
So What is  Bottling and who is a Bottler ?
Bottling is taking a spirit that is in a bulk container (be it a barrel, 200 gallon tote, tank car, etc.,) and bottling or packaging it into a retail form either in an automated or hand bottling line or process. They may filter or blend different bulk containers of the same spirit before bottling but they do not add additional ingredients or treatments to change the character of the spirits.
A bottler is someone who takes a bulk spirits and bottles it.
Spirit Architect 
This is a new term to describe someone who is not a distiller of a spirit but contracts with or directs a distiller to make a spirit for them in specific ways and/or using specific ingredients and/or other treatments, formulas, techniques, to make a spirit to their specifications as directed by them.
This is in some ways quite similar to contract brewing except for distilling and distilled products.It is further differentiated from rectification as the Spirits Architect is involved at the conception or beginning of the product and not taking a product and rectifying it. All the processes are done by a distiller at the Spirit Architects direction or specification.
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A Modest Proposal on How to Define Craft Distilling Through Information

Disclosures, Good Writing, and Consumer Education vs. Rules and Guidelines
By Christopher Carlsson,

This piece is a result of a long discussion on what defines craft distillation (at a bar, with distillers of course) and after a full day of us all watching more lying, obfuscation, and innuendo by numerous products and their representatives who knowingly or unknowingly were trying to pass off mass produced commercial products as handmade or craft at a liquor store tradeshow, I decided to write this up.

Given all the recent controversy on what is, or what is not, a “craft” or “handmade spirit” and all the attempts to spin defintions to fit all sorts of operations for various partisan or financial reasons; has given rise to creative, if not outright bogus representations or implications based on non disclosure, and/or hiding origins, ownerships, or provenance of spirits being sold. This proposal is an attempt to cut through some of the smoke and mirrors that are rife in the industry now.
Rather than depend on regulations, guidelines, labeling, and fairy stories, I propose we use information and disclosure to inform people about craft distilling and how a distillery and its products can be defined or identified as craft.

Below is a list of questions or talking points to ask yourself and use – listing them on your website, company information handouts, or other PR materials to inform and promote your company and products to the public.

These questions or talking points will rapidly distinguish a real craft operation (or degree of craft at least) from the Potemkin village type operations that cannot answer these questions. They should be used by both the industry to write better profiles and also be asked of distillers by consumers, journalists, and authors and should be answered as fully as possible to show what you are about.
Now some of these questions may seem like they border on proprietary information but most of the information outlined here can be found through public records or direct observation at least in terms of equipment, so why not be forthcoming and educational on most points?
The information will be useful to not only distilling geeks but also fans of your products so they can talk more knowledgeably about your products and exactly how they came to be. This information could be in the body of a handout or website or could be placed in a separate area or link so as not to make your initial piece too wordy. Suggested titles- Geeky Details, Under the Hood, TMI, What Makes Us Craft, Our Craft Credentials, etc.

Materials – Are you farm to flask or tree to bottle? Do you grow your own raw material?
Is your feedstock grown locally, or at least in your state? What percentage is it of total ?
Water – Source and characteristics, e.g. reverse osmosis,well water, limestone, deep aquifer, glacial melt, tap water.

Processing – Do you process your feedststock yourself as in malt, grind, press, macerate, or otherwise prepare.

Fermentation – Do you ferment material in house?, If so – fermentation time?, special yeasts?, music played?, agitation?, special sugars or unique aspects to your fermentation?
or do you buy already fermented product e.g. beer or wine type material and distill it? What types, origins, abv, etc.

Still – Manufacturer, Size,Type Pot, Column, Pot Column Hybrid, Alembic, Charentais , etc., etc.,), Material (copper, wood, and or stainless? In the case of column types, number of plates, height, etc., in the case of pot stills: lyne arms, shape, reflux, thumpers, etc.) type of firing (gas ,coal, or wood direct flame, steam, electric, water bath etc.. Any other points that make your distillation equipment interesting or unique is illuminating and appreciated.

Distillation Methods – Any unique points?
Hand Bottling or Automated Line ?
Hand applied labels ?

Capacity or current production (preferably in bottles – not cases, or gallons)

Any and All Natural/Green/Environmentally Friendly Points
Organic, natural, non GMO, or local material?, Direct from grower?, Fair Trade
Feedstock recycling for reuse by farmers or others for feed, composting etc.,
Waste heat recycling for preheating, heating building, gardens,ponds, etc.,
Heads and tails Recycling as in burning in patio heaters, donating for cleaning etc.,
Recycled glass or paper for bottling and labels ? Ink (organic?), Percentages ?
Any recycling programs for bottles, other waste products?

Employment – How many?, Local?, Minority, women, veterans etc.,? Training programs?. Compensation (minimum wage, health insurance etc.,)

Economic Impact – How many people do you directly employ, how many other people do you spend money with – especially locally and what percentage ? Considering label and graphics, printing, sales, advertising, freight, legal, etc., etc., ) Overall how much do you put in/spend in th local economy (10, 30, 50,100 mile radius etc. )

What’s Your Story?
Who are you ?
Why do you do this?
Relatives, Friends work there?
Funding/Capitalization (Life savings, house, credit cards, bank, grants, (if you think it adds to your story or adds sympathy/empathy)
Ownership/Principal Investors – Do you own and operate the distillery ?, Do family members?, Workers CoOp? etc.,
Startup Challenges
Human Interest
Children and Pets
Charitable Causes/Donations
Do you have tours or invite people ( especially industry people) to the facility to learn more?
Do you have handouts, visual aids, or AV materials both for tours and talks outside the distillery ?
Do you reach out to the local community and tell them what you do?
And while pictures are worth a thousands of words, hard information with pictures is even better !
Don’t depend on truth in labeling – depend on truth in disclosure and information
And no, we did not come up with point systems so you could pull rank on each other. You can do that by yourselves.

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