The alcohol

The permit, before commencing business

Updated October 2026

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What it says And separately for dealers Why denatured at all The consequence of using it outside the rules Which is the real exposure Supporting data comes with the application There is a waiver provision, and it is discretionary References

Before commencing business is the operative phrase, and it is in the regulation.

What it says

A person who desires 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, Form 5150.9. The same applies to anyone wanting to recover denatured spirits from articles.

And separately for dealers

A person who desires to withdraw and deal in specially denatured spirits files the same application and obtains the same permit before commencing business. So a reseller of the alcohol is caught as well as a user of it.

Why denatured at all

Denaturing makes the alcohol unfit to drink, which is what takes it out of the beverage tax system. Specially denatured alcohol is denatured in a formula suited to a particular industrial use, which is why its use is permitted rather than open.

The consequence of using it outside the rules

All the laws and regulations regarding non-denatured alcohol, including those requiring payment of the distilled spirits tax, apply to specially denatured alcohol produced, withdrawn, sold, transported or used in violation. And the person who did so is required to pay that tax.

Which is the real exposure

Not a fine for a missing form but liability for the distilled spirits tax on the alcohol. For a business of any size that is a figure worth understanding before the first drum arrives.

Supporting data comes with the application

All data, written statements, certifications, affidavits and other documents submitted in support are considered part of the application, and evidence of the signer’s authority to execute it has to accompany it.

There is a waiver provision, and it is discretionary

The appropriate TTB officer may waive detailed application and supporting data requirements where doing so poses no jeopardy to the revenue, and that waiver terminates when the conditions justifying it no longer exist. It is not something to plan around.

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

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.