Tools and directories

The check, before the first case

Updated October 2026

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One: do you have the permit?Two: what is the flash point, and the packing group?Three: ground or air, and does the table reference the exception?Four: does the fitment exist on your neck?Five: has the label survived the formula?And keep a weighed control bottle File the five answers with the formula References

Five questions. Two of them have lead times measured in weeks.

One: do you have the permit?

If you will withdraw and use specially denatured spirits, the application on Form 5150.22 and the permit on Form 5150.9 come before commencing business. Using it without one brings liability for the distilled spirits tax on the alcohol.

Two: what is the flash point, and the packing group?

Because that sets the limited quantity inner packaging limit at 0.5 L, 1.0 L or 5.0 L. Every bottle on this shelf clears all three, so the limit you actually work to is the 30 kg gross package weight.

Three: ground or air, and does the table reference the exception?

The limited quantity relief is only available where 173.150 is referenced for your material in the 172.101 table, and air removes the labeling relief and adds the 173.27 requirements. Confirm with the carrier you will actually use.

Four: does the fitment exist on your neck?

Check the bottle’s finish against the verified closure list on its own page, not against a diameter. 20-400 and 20-410 are a digit apart and not interchangeable, and on this shelf that is the specific trap.

Five: has the label survived the formula?

Labeled, filled, wiped down the side, handled for a week. Facestock, adhesive, ink and any overlaminate all have to hold, and in this category the label is most of what the buyer is paying for.

And keep a weighed control bottle

Filled, sealed and weighed at intervals, so you know whether alcohol is leaving through the closure. One bottle, and it answers a question no datasheet will.

File the five answers with the formula

Permit, flash point and packing group, shipping route, bottle and fitment pair, label specification. A reformulation can move the packing group, and then the shipping answer and possibly the case size move with it.

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

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.