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Updated October 2026

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What this covers The permit And the tax consequence of getting it wrong The hazard class The solvent And a fit problem you would not guess Two archetypes name parts their shelf does not hold References

If your product is mostly alcohol, two of your three hardest problems are not about the bottle.

What this covers

Perfume, eau de parfum, cologne, body mist, hair perfume and linen spray, plus perfume oil, solid perfume and roll-on perfume. Nine leaves across four genuinely different archetypes, which is better taxonomy than most groups here get.

The permit

A person who desires to withdraw and use specially denatured spirits shall, before commencing business, file an application on Form 5150.22 and obtain a permit on Form 5150.9. Before commencing business is the phrase that matters.

And the tax consequence of getting it wrong

All the laws and regulations for non-denatured alcohol, including the distilled spirits tax, apply to specially denatured alcohol used in violation of the rules, and the person who did so is liable for that tax. That is a large number attached to a paperwork failure.

The hazard class

A high-alcohol fragrance is a Class 3 flammable liquid. There is a limited quantity exception with real relief in it, and it comes with inner packaging limits, a 30 kg gross cap and a different answer for air.

The solvent

Which is the part that reaches the shelf. The archetype note says it in one line: high alcohol attacks plastics and adhesives, so glass, sprayer or roll on. All 63 containers on the main shelf here are glass, and that is not a style choice.

And a fit problem you would not guess

31 of those 63 bottles are 20-400. The catalog has 34 fine mist sprayers and only 4 of them are 20-400; the rest are on 20-410 and 24-410. The fitment section is about that arithmetic.

Two archetypes name parts their shelf does not hold

The solid perfume archetype is called a tin and its shelf has no metal on it. The roll-on archetype has no roller balls. Both have real answers elsewhere in the catalog, and the pages name them.

References

27 CFR 20.41, Application for industrial alcohol user permit. A person who desires to withdraw and deal in, or to withdraw and use or recover, specially denatured spirits shall, before commencing business, file an application on Form 5150.22 for and obtain a permit on Form 5150.9. law.cornell.edu

27 CFR 20.31, which applies all the laws and regulations for non-denatured alcohol, including the distilled spirits tax, to specially denatured alcohol produced, withdrawn, sold, transported or used in violation of the rules, and makes the person who did so liable for that tax. law.cornell.edu

49 CFR 173.150, Exceptions for Class 3 (flammable and combustible liquids). Limited quantities are excepted from labeling unless offered by aircraft, and from specification packaging when in combination packagings, with inner packagings not over 0.5 L for Packing Group I, 1.0 L for Packing Group II and 5.0 L for Packing Group III in a strong outer packaging, and no package exceeding 30 kg gross. The exception applies only where this section is referenced for the material in the 172.101 table. law.cornell.edu

Written from federal regulation and from measured catalog data, not from a perfumer’s bench. Whether a formula is Packing Group I, II or III follows from its flash point, and whether the limited quantity exception is available depends on the 172.101 entry for the material. Nothing here is a permit, a classification or a finding that a package complies.