TTB Informal Advice on Brewers Producing Hand Sanitizer

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The following presumes a brewer wants to make hand sanitizer from alcoholic material they produce at the brewery (versus buying ethanol from a distillery). 

There are two options, both of which involve being qualified as a distilled spirits plant (DSP):

  1. The brewer may file an amendment to alternate the brewery with a distillery, or 
  2. The brewer may establish the distillery as a separate operation in the same facility as the brewery.  If space is taken from the brewery in order to make room for the distillery, the brewer must also amend the Brewers Notice to remove that part of the brewery from the Brewery Premises, and there must be some minimal indication/form of separation between the two.  

See 27 CFR 19.143 in the DSP regulations and 27 CFR 25.81 in the beer regulations.

Interested brewers should apply via Permits Online, as there is very limited ability to retrieve paper applications.  TTB is currently expediting all hand sanitizer related applications.

A few other things to keep in mind:

  • In addition to applying for the permit, please read the latest hand sanitizer guidance Production of Hand Sanitizer to Address the COVID-19 Pandemic (3/26/20).  Note that federal policy around hand sanitizer production is still evolving, so please check frequently for the latest TTB guidance.
  • Also, at this time hand sanitizer producers must follow the most recent FDA guidance, but please know that FDA guidance may also change in the future.
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