« on: March 07, 2012, 03:46:30 PM »
I've been reading statutes until my head hurts (doesn't take long). Anyway, here are some of the things I've come up against. I'll update this as I make any progress.
In my state (Missouri), there is no mention of "honey" in any statutes or definitions for any type of alcohol. I talked to my local state Alcohol agent, who informed me he "thinks" using honey would require a generic "Alcohol Manufacturer's" license.
I also asked him about specific requirements for the facility (drains, sinks, etc) and he said the state would license whatever the TTB approves. When I asked who is responsible for verifying compliance, he said both the TTB and the state Alcohol and Tobacco Control agency are responsible. The TTB guidelines just say the facility must be "appropriate" for whatever type of brewery/winery/distiller you're running, but don't have any specific guidelines.
The TTB says that "Honey wine" falls under the category of "wine from other agricultural products." So I'm not sure how it'll work if I get TTB approval for a winery, but then have to get a non-winery state license. There are a number of benefits to being licensed as a winery in Missouri, including direct-to-consumer sales and lower licensing fees.
I've contacted the TTB directly about who decides if a facility is "appropriate" and what criteria they use. After that, I guess I'll contact the head office for the state Alcohol control agency re: honey in wine.
The applicable statute I found for Missouri wine: "Domestic wine is wine containing not in excess of fourteen percent (14%) of alcohol by weight and manufactured exclusively from grapes, berries and other fruits and vegetables grown in Missouri."
Apiaries in this state are regulated by the department of agriculture, so I don't understand where honey fits in, if not with fruits and vegetables. I know there are a wineries here that make mead, and I have a hard time believing the alcohol agent who inspects those wineries doesn't know if honey-wine requires a different license than a winery.