Getting started

From formula to bottle

Updated October 2026

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One: sort the alcohol out Two: settle the concentration Three: decide how it ships Four: choose the bottle, which is glass Five: choose the fitment, and check it actually fits Then test the label against the product Keep the five answers together References

Five steps, and the first one has to happen before you commence business.

One: sort the alcohol out

If you intend to withdraw and use specially denatured spirits, the application and permit come before commencing business. That is a lead time to plan around rather than a form to file when somebody asks.

Two: settle the concentration

Which decides the flash point, which decides the packing group, which decides the inner packaging limit under the limited quantity exception: 0.5 L, 1.0 L or 5.0 L. So a formulation decision sets a packaging limit.

Three: decide how it ships

Ground and air are different answers. The limited quantity exception drops the labeling requirement except by aircraft, and for air the package has to meet further requirements and only materials authorized aboard passenger aircraft qualify.

Four: choose the bottle, which is glass

Because the alcohol attacks plastics and adhesives, and because every container on the main shelf is glass. 63 of them, 7 to 120 mL, with 20-400 the dominant finish at 31.

Five: choose the fitment, and check it actually fits

This is the step that catches people here. The sprayer, the roller ball or the dropper has to exist on the neck your bottle carries, and on this shelf that is a narrower question than it looks.

Then test the label against the product

Alcohol on the outside of a bottle lifts facestock and smears ink, and in this category the label is most of the perceived value. Wipe the formula down the side of a labeled bottle and look at it a week later.

Keep the five answers together

Permit, concentration and flash point, shipping route, bottle, fitment. A reformulation can change the packing group, which changes the shipping answer, which can change the size you sell.

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

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

29 CFR 1910.1200, Hazard Communication, which sets what a shipped container of a hazardous chemical carries and requires a safety data sheet. 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.