(IMBIBE+BLOG)

At Strike & Techel, we don’t just write legal briefs. Check out our blog about the ins and outs of alcohol beverage law.

Join our mailing list:

Search Imbiblog by keyword:

Browse posts by category:

Imbiblog is published for general informational purposes only and is not intended as legal advice.

Category archives for “Uncategorized”

Custom Crush vs. Alternating Proprietorship: Starting a Cheaper Wine Business

October 13th, 2014

There is a long running joke that it is easy to make a million dollars in the wine industry, you just start with two million dollars. Joking aside, there are relatively low cost ways that you can get started in the wine business, without having to invest in planting your own vines and building your own winery. These options allow you to get started making and building your brand without having the considerable overhead of vineyards and winery buildings. Two ways exist of doing this: you can enter into a custom crush relationship with an existing winery to make wine for you, or you can get your own winery license, based at an existing licensed winery, in what is referred to as an alternating proprietorship or AP arrangement. In both cases, you own and develop your own wine brand or brands. We have put together some information on both systems here, and also recommend that you read the full Industry Circular from the Alcohol and Tobacco Tax and Trade Bureau (TTB) on the differences between them.

Custom Crush

In a custom crush situation, you contract with a winery to make wine for you. Even if the grapes that are used for the wine are grown or purchased by you, the produced wine belongs to the winery until state and federal excise taxes are paid and it is sold to another properly licensed entity. The winery gets the label approval and maintains all records and reports. You, as the brand owner, generally obtain a wholesale license so that you can buy the tax-paid wine from the winery and then resell it to wholesalers and retailers, depending on your state licensing. Each state has a different way of managing this. In Oregon, for example, custom crush customers often get a state winery license alongside a federal wholesale license. In California, it is possible for a wholesaler to also obtain a retail license and market wine direct to consumers, although shipping to other states with such a license is limited to the small number of states which allow an out-of-state retailer to ship to their residents.

Alternating Proprietorship (AP)

The TTB will allow licensed premises to alternate between owners, such as in an AP agreement where more than one winery is licensed in the same location. Premises can also alternate between types of licenses, so that a facility can alternate between a winery and a brewery or distillery, for example. In an AP situation, the TTB will allow more than one licensee to operate a winery in the same location, and even for some of the same staff to be used, provided that each owner makes independent decisions evidencing authority and control over the winemaking process. The TTB requires and will review the written AP agreement between the parties, often referred to as “host” and “tenant,” to make sure that each licensee has a bona fide plan to conduct its own winery operations. Although an AP arrangement involves more permitting and recordkeeping than the custom crush approach, it carries some significant benefits. First, the AP tenant is licensed as a winery and will be able to benefit from the rights of a winery licensee in that state. These can include being able to sell direct to consumer in almost all states, operate one or more tasting rooms, and produce or blend other types of alcohol. Second, an AP tenant is likely to be eligible for the small domestic producer tax credit, as production is based only on the AP tenant’s production, which is not likely to exceed 250,000 gallons in the start-up phase (note that there are no minimum federal production requirements for a winery but California, for example, requires at least 201 gallons of wine a year to be made by a licensed winery). It should be noted that winery licensing under an AP agreement may trigger some grape sourcing requirements that you should be aware of, and you will need to research local planning issues more closely in an AP structure than a custom crush relationship.

If you are interested in learning more about custom crush and alternating proprietorships in California or elsewhere, contact one of the attorneys at Strike & Techel.

Imbiblog is published for general informational purposes only and is not intended as legal advice. Copyright © 2014 · All Rights Reserved ·

TTB Reconsiders Use of “Estate Bottled” Following a Winery Sale

May 21st, 2014

To be labeled as “estate bottled,” a wine must be, among other things, made from grapes grown in an American Viticultural Area, on land that is owned or “controlled by” the winery, and the winery must crush, finish, age and bottle the wine in a continuous process.

Previous guidance from the Alcohol and Tobacco Tax and Trade Bureau (“TTB”) suggested that a wine would not be entitled to use the “estate bottled” designation if a change of ownership of the winery occurred at any point during the winemaking process, because the new owner technically would not have “controlled” all phases of the process. To address this issue, sellers and buyers of wineries that produce “estate bottled” wines would sometimes enter into an Alternating Proprietorship Agreement (“AP”) whereby the seller would maintain its bonded winery operations until all wine in process at the winery as of the closing date had been bottled and labeled. This approach was difficult for both sellers and buyers, given that the AP could be in effect for a lengthy period of time depending on which stage of production the “estate bottled” wine was in.

In a recent private letter ruling, the TTB advised that it has reconsidered its position and that the proprietor of a winery can  use an “estate bottled” designation for wine that was grown and fermented by a predecessor proprietor and bottled by a new proprietor (provided the wine also met the other requirements under 27 C.F.R. § 4.26). The ruling provides that the ownership of a winery may change while the wine is in process as long as the bottling winery does not change. The TTB further explains that the definition of “controlled by” refers to the land on which the grapes are grown and the winery operates, as opposed to the owner of such land. With a change in winery ownership, the “estate” land is not altered, and thus the new owner can maintain the “estate bottled” designation.

This guidance from the TTB should come as a welcome relief to potential purchasers and sellers of wineries that produce “estate bottled” wines.

For questions about the acquisition or sale of a winery, please contact one of the attorneys at Strike & Techel.

Imbiblog is published for general informational purposes only and is not intended as legal advice. Copyright © 2014 · All Rights Reserved ·

NYSLA Expands Suppliers’ Ability to Entertain Consumers

May 6th, 2014

Suppliers’ ability to run events for consumers in the New York market has been up in the air for a number of years now, and especially since the industry consent orders in 2006. Now, the New York State Liquor Authority (SLA) has given helpful and detailed guidance on how these events can be run.

Supplier Purchases of Alcohol from On-Premise Retailers – #2014-8

This new SLA Advisory covers the ways in which suppliers and wholesalers may purchase alcoholic beverages from on premise retailers for consumers. Under the consent orders issued in 2006, there were three ways in which this could be done: (1) on an incidental basis; (2) for employees or private guests at an invitation-only event; or (3) at a bar spend promotional event open to the general public. The new advisory clarifies the scope of those activities and also expands on them.

Purchases for Consumers on an Individual or Incidental Basis

This is unchanged from SLA’s prior position. It is not intended to be an option for promotional events. It permits a supplier rep to buy themselves a drink and to buy a drink for individual patrons of a retailer.

Business Meetings and Private Events

- Business meetings or business entertainment

This means a gathering of a supplier employees, and/or representatives for entities that do business with a supplier (including other suppliers, distributors and retailers). There must be a legitimate business purpose for the meeting, like discussing product sales, new product introductions etc. It does not include holiday parties or other special occasion events. There are no spending restrictions, or limits on the number of meetings at any particular on premise location. The event must be in a reserved area (can be as little as one table), and at least one supplier employee must be present. Retail licensees and their employees can be invited and an invite can be sent to all employees of a particular retailer.  Media reps can be present.

- Private invitation only events closed to the general public

This is an event not conducted for a business purpose or for promotional purposes. It must be a gathering of invitees who have an identifiable affiliation with a supplier (e.g., a party for employees, vendors or business associates), or a common affiliation or relationship with each other (e.g. journalists, sports teams or non-profit organizations). The language of the advisory makes it clear the group cannot just be a large gathering of a group of consumers or potential consumers without meaningful commonality other than an attempt to market or target a demographic. Invitations must be sent by a supplier to invitees by individual name, each such invitee may bring only one guest. Invites can be by phone, e-mail, letter, in person, etc. Invites cannot be in any type of media advertisement or generic communication to anyone wishing to attend and cannot be sent to a “mailing list” of consumers obtained or created by a supplier. The event must be in a reserved area (can be as little as one table) and at least one supplier employee must be present. Despite the stated non-business and non-promotional purpose of the events, retail licensees and their employees can be invited, as can the media.  A supplier cannot send a general invite to all employees of a retailer or a retail chain.

Promotional Events Open to the General Public – No Invitation Required

Prior to the advisory, a bar spend was limited to $500 (plus 20% tip) and no more than six events per retailer, per year. Now, the limit is $700 (plus 20% tip), and no more than ten events per retailer, per year. A supplier cannot purchase food, non-alcoholic beverages, or anything else from the retailer for such an event. These events can now be advertised, identifying the time, date and location. Invites may also be sent to members of the general public, but the event cannot be restricted to people that received such invitations. There is no longer a need to submit statements after these events; a supplier must maintain a record of each event for two years that includes date, time, location and duration, brands that were purchased, and names of supplier reps or agents who conducted the event.

Promotional Events Open to the General Public – Invitation Required (“Brand Experience Events”)

This is a new category of events which will be extremely helpful for supplier marketing and promotions in New York. The advisory refers to these as “brand experience” events that are “much larger” than bar spend events. At a brand experience event, a supplier can spend up to $10,000 (plus 20% tip), and may purchase alcoholic beverages, non-alcoholic beverages and food. A supplier can also apply to the SLA for advance permission to spend more than $10,000 for an event. A supplier can have up to six such events per retailer per year (whether the event is at a retail premises or whether a retailer caters the event, as catering permits in New York are only held by on premise licensees). Attendees at these events must be invited and an event can be restricted to invitees only. A supplier can invite people individually (by phone, letter, e-mail, in person, etc.), or can also place media advertisements including invitations, generic communications inviting anyone who wishes to attend to register, and “mailing lists” of consumers. A supplier can advertise brand experience events, including date, time and location. Each person registered as an invitee may bring one guest. A supplier must maintain a record of each event for two years that includes date, time, location and duration, brands that were purchased, and names of supplier reps or agents who conducted the event.

Events Where the Supplier or Wholesaler Provides the Alcoholic Beverages

In a very helpful clarification, the new advisory notes that it is only intended to cover occasions where a supplier is purchasing alcoholic beverages from a retailer. It goes on to discuss the fact that a supplier may provide alcoholic beverages for an event without being bound to any of the above exceptions.  Specifically:

- Not-for-profit organizations

A supplier may donate product to a not-for-profit organization for an event which the not-for-profit organization is conducting, either at licensed premises or at an unlicensed location with a permit from the SLA. A supplier can also receive promotional benefits in exchange for the donation to the organization. The only real restriction is that a supplier cannot choose the retailer for the event. The new advisory does not use the same restrictive “bona fide charitable organization” language used in the tasting advisory published in July, 2013. It appears that non-charitable not-for-profit organizations qualify for these events.

- Private/Brand Experience events at unlicensed locations

The new advisory allows a supplier to conduct a private invitation-only event or a brand experience event at an unlicensed location and to provide the alcoholic beverages for that event without having to fit into one of the four event types above. Note that any unused alcoholic beverages must be removed by a supplier after any event under this section.

An appropriate permit must be in place for these events. This means that a supplier should use a retail licensee caterer for such events at this stage. We anticipate a new supplier event permit will available in the future.

Imbiblog is published for general informational purposes only and is not intended as legal advice. Copyright © 2014 · All Rights Reserved ·

Brewing Beer in California

April 14th, 2014

With the explosive growth in craft beers and micro and nano and other really, really small breweries, we at Strike & Techel wanted to put together some helpful tips for anyone looking to brew beer in the state. If you want to make beer commercially, these guidelines will help you work out the best way to start your new business. You will find three ways to get going in the guidelines: small beer manufacturing, beer manufacturing (over 60,000 barrels of beer), and brewpub operations where you get to brew beer and sell it to people in a restaurant or pub setting.

Contact one of the attorneys at Strike & Techel if you have questions about brewing beer in California or other states.

Imbiblog is published for general informational purposes only and is not intended as legal advice. Copyright © 2014 · All Rights Reserved ·

Nevada Signals Intention to More Actively Monitor Trade Practices

March 5th, 2014

Almost three years ago now, as reported on Imbiblog here, the TTB accepted its largest set of offers in compromise ever, for trade practices violations. Some of the biggest names in the business agreed to pay hundreds of thousands of dollars to the TTB even though they denied violating any laws or regulations. The allegations of trade practice violations came from participation by the companies in the 2008-2009 Harrah’s Nationwide Beverage Program. Unlike notable earlier trade practice investigations by the TTB, where there was state participation and a parallel investigation, there were no allegations made against retailers involved in the program, and no fines or penalties assessed against retailers (see for example the 2004-2009 joint investigation by Illinois and TTB into payments made by suppliers and wholesalers to Sam’s Wine & Spirits, Inc., then the largest wine retailer in the country, and its captive third party marketing organization Skyline Marketing, Inc.). The 2011 settlement by TTB was acknowledged to result from a retailer-initiated promotional program. Given that the TTB has extremely limited jurisdiction over alcohol retailers, however, the agency was unable to enforce any allegations against Harrah’s for the promotion. Had the State of Nevada participated in the investigation, it is more likely that charges could have been brought.

Now, the Office of the Attorney-General in Nevada has come out with an open letter to retailers, wholesalers and suppliers of liquor in Nevada in what appears to signal an intention to focus more attention on trade practice issues in the State. The advice contained in the letter is phrased as a “reminder” to the industry of prohibited and restricted activities. It covers the following issues:

-          No loans from wholesalers to retailers of money or other thing of value, no investments by a wholesaler in a retailer, no complimentary furnishing of premises or equipment, and no joint operation of a retail business;

-          Adherence to strict payment terms, with no preference accorded by wholesalers to certain retailers, and with a cessation of sales and monthly service charges in case of delinquency;

-          No substitution of brands without consent, and no delivery of unwanted or unnecessary inventory;

-          No required boycotts of other suppliers;

-          No price fixing down the supply chain by suppliers imposing resale prices on wholesalers, and no profit splitting with the supplier getting a specified portion of the wholesaler’s profit margin;

-          No excessive marketing contributions being required by suppliers of their wholesalers, for promotions outside the wholesaler’s market or beyond the terms agreed by the parties;

-          Strict adherence to the quoted price from suppliers to wholesalers;

-          No discrimination by suppliers among wholesalers (note that Nevada has a franchise law meaning that this refers to discrimination between wholesalers in different parts of the state as only one wholesaler can be appointed in any given market); and,

-          No deceptive trade practices.

The letter refers to concerns with illegal terms or incentives by industry members looking for a competitive edge in the market. It notes that the Attorney General has jurisdiction over these issues and is required by law to take appropriate legal action to enforce the provisions of law setting forth the restrictions above. The Attorney General’s office recognizes in the letter its duty to investigate and prosecute deceptive trade practices in Nevada. Should the type of circumstances in the TTB’s investigation in 2011 arise again, it will be very interesting to see what action is taken by the state in light of this clear signal that it is unlikely to sit by if unlawful trade practices occur in Nevada.

If you have any questions about trade practice issues, in Nevada or elsewhere, contact one of the attorneys at Strike & Techel.

Imbiblog is published for general informational purposes only and is not intended as legal advice. Copyright © 2014 · All Rights Reserved ·

TTB Updates its Position on Gluten-Free Label Claims

February 11th, 2014

On Tuesday, the Alcohol and Tobacco Tax and Trade Bureau (“TTB”) issued an Announcement regarding its treatment of “gluten-free” claims on alcoholic beverage labels. As we previously blogged here, TTB has been looking into the issue of gluten-free labeling since at least 2012, and TTB Ruling 2012-2 implemented a policy of allowing the term “gluten-free” only on the labels of products that are produced without any ingredients that contain gluten. For products made from gluten-containing materials, the 2012 Ruling implemented several requirements, including: a) a statement that the product is “Processed or Treated or Crafted to remove gluten;” b) a qualifying statement to inform consumers that (i) the product was made from a grain that contains gluten, (ii) there is currently no valid test to verify the gluten content of fermented products, and (iii) the finished product may contain gluten; and, c) a detailed description of the method used to remove gluten from the product.

TTB explains in its most recent announcement that it has finished its review of the FDA’s rule on gluten-free labeling, and has updated its requirements accordingly. TTB will continue to allow the term “gluten-free” only on the labels of products that are produced without any ingredients that contain gluten. However, for products made from gluten-containing materials, TTB has lessened the labeling requirements, and now provides that such products may be labeled with a statement that the product was “processed, “treated” or “crafted” to remove gluten, if that claim “is made together with a qualifying statement that warns the consumer that the gluten content of the product cannot be determined and that the product may contain gluten.” Labels no longer require a detailed description of the method used to remove gluten from the product.

If you have any questions about alcoholic beverage labeling, contact one of the attorneys at Strike & Techel.

Imbiblog is published for general informational purposes only and is not intended as legal advice. Copyright © 2014 · All Rights Reserved ·

Getting Started in the Business: Entity

January 15th, 2014

This blog entry is part of a continuing series discussing important steps to get started in the alcoholic beverage industry. In addition to choosing a location for your business (discussed in a previous post, here), and before you prepare the applications to obtain the license(s) required to operate your business (discussed in a previous post, here), you will also need to consider what type of business entity should be formed in order to operate your business.

We usually counsel clients to hold their alcoholic beverage license under an entity, rather than as an individual.  Formation of an entity that is separate and distinct from its owners offers protection against certain liabilities and may be advantageous from a tax perspective.

The type of entity (e.g., corporation, limited liability company, trust, etc.) and the domicile (state) of the entity can impact how the entity is taxed.  Your tax advisor may have an opinion on these issues.  If the entity is not domiciled in California and you intend to apply for a California ABC license, the entity will have to qualify to do business in California before you can file your applications. You may also need to register a fictitious business name in the county in which your business will operate and obtain a local business license(s).

In order to establish an entity in California, you will have to file Articles with the Secretary of State.  You will also need to prepare corporate bylaws or an LLC operating agreement, depending on which type of entity you form.  These documents are very important, as they set forth the specifics about ownership percentages, voting rights, profit distributions, etc.  Bear in mind that certain changes in ownership, such as added shareholders/LLC members can affect your alcohol licenses.  It is wise to consider carefully who will be an owner of the business entity and whether any ownership changes are likely to occur before submitting your license applications.

Contact one of the attorneys at Strike & Techel if you have questions relating to forming a business entity in order to get started in the alcohol beverage business.

Imbiblog is published for general informational purposes only and is not intended as legal advice. Copyright © 2014 · All Rights Reserved

Getting Started in the Business: Licensing

December 12th, 2013

This blog entry is part of a continuing series discussing important steps to get started in the alcoholic beverage industry. Once you have pinpointed a location for your business (discussed in a previous post, here), you will need to obtain a license, or a combination of licenses, before you commence operations.  To determine what type(s) of license(s) you need, here are some answers to questions you may be asking:

*   Do the Tied-House Laws Permit Me to Hold the Licenses I Want?  Federally and across all states, “tied house” laws generally prohibit the same person or entity from having an ownership interest in alcohol beverage businesses in more than one of the 3 tiers -manufacturing/importing, distribution and retail.  (To learn more about tied house laws, review this post.)  However, that restriction is far from absolute.  Many statutory exceptions have been carved out of the 3-tier system to permit cross-tier licensing and the resulting patchwork of exceptions can be difficult to comprehend.  For example, in California, wineries can also own restaurants (subject to restrictions) and certain off-sale retail stores.  Small breweries (less than 60,000 barrels/year) can own on-sale retailers but large breweries cannot.  Beer and wine wholesalers cannot also be retailers, unless they sell only wine through the retail store.  Other states have their own set of hard-to-explain exceptions.

*   What Does My License Permit Me to Do?  The general rule is that manufacturers sell to wholesalers; wholesalers sell to retailers; and retailers sell to consumers.  But this, too, is riddled with exceptions.  California wineries and breweries can sell their products directly to retailers and consumers without using a distributor, but distilled spirits manufacturers can sell only to distributors and cannot themselves hold a distributor license.  Rectifiers, on the other hand, can act as their own distributor and sell their products – and spirits products made by anyone else – directly to retailers.  Moreover, you may need more than one license to operate your business.  For example, if you are going to be operating a distillery, you will need a Type 4 (Distilled Spirits Manufacturer’s license), and a Type 6 (Still) license.  If you are importing distilled spirits from outside of California and distributing them to retailers you’ll need a Type 12 (Distilled Spirits Importer), and a Type 18 (Distilled Spirits Wholesaler).  California issues dozens of different licenses so it is important to know exactly what you want to do, which licenses are needed to accomplish it, and whether you are eligible to hold them.

*   What are the Processing Times to Obtain a License?  In California, it takes about 90-120 days to process an application for a new license, and slightly less time to transfer an existing license at a premises that is already licensed. It will take longer to process an application that is incomplete, contested by neighboring residents or the local authorities, or filed incorrectly.  Also keep in mind that the ABC cannot issue a license until it has received confirmation from the City/County that all required use permits have been obtained.  Each applicant will be assigned a local ABC investigator to handle the application until the process is completed.  Currently, U.S. Alcohol Tobacco Tax Trade Bureau (“TTB”) licenses are processing in about 90 days, similar to California licenses.

*   May I Obtain a Temporary Permit?  Provided that you are transferring an existing license at an already licensed premises, the California ABC may grant a temporary permit so you may operate your business while the license transfer application is being processed. A temporary permit is not available in connection with applications for new licenses or applications to transfer existing licenses to a premises that has not been previously licensed.

*    What Are the Costs Involved?  Depending on what type(s) of license(s) applied for, the cost can vary considerably.  A schedule of license costs is available here.  Some retail licenses are limited in numbers and must be purchased on the open market.  Prices for these licenses vary greatly by type and location.  For instance, a Type-47 (On-sale general eating place) may sell for $200,000 in San Francisco, whereas the same type of license in Fresno County currently only costs $12,000.

In conjunction with your ABC application, you may also need to obtain other federal, state or local licenses/permits.   In California this may include, for example:  federal licenses through the TTB; a certification from the Secretary of State that you are qualified to do business in the state; and a sales tax permit from the State Board of Equalization.

Contact one of the attorneys at Strike & Techel if you have questions about applying for a license to get started in the alcohol beverage business.

Imbiblog is published for general informational purposes only and is not intended as legal advice. Copyright © 2013 · All Rights Reserved ·

Happy Repeal Day! 80 Years Ago Prohibition was Repealed

December 5th, 2013

On December 5, 1933, the 21st Amendment to the United States Constitution was ratified, thus repealing the 18th Amendment and marking the end to enforcement of the Volstead Act and the official end of the period known as “Prohibition.”  Most historians agree that Prohibition was a failure.  Born out of the late 19th Century formation of temperance societies, like the Woman’s Christian Temperance Union, Prohibition was intended to strengthen families and reduce social problems caused by overconsumption of alcohol.  Instead, it brought more than 10 years of increased crime, and little or no decrease in alcohol consumption (but it did give rise to great terms like Speakeasy, the Real McCoy, and Blind Pig).  After 13 years, 10 months, 19 days, 17 hours and 32.5 minutes of Prohibition, the Noble Experiment finally ended and alcohol could once again be purchased legally in the U.S.

Happy Repeal Day from everyone at Strike & Techel.

Cheers!

Getting Started in the Business: Location

December 2nd, 2013

This blog entry is part of a continuing series discussing important steps to get started in the alcoholic beverage industry. If you intend to obtain an alcoholic beverage license for your business, you’ll need to have a location for the business before you apply.  In selecting a location, you should consider the following factors.

 

State:  Each state has different licenses available, charges different fees for its licenses, and applies different rules to its licensees.  Further, some states move faster than others in issuing licenses.  Once you’ve settled on a business model, you should choose a state that is favorable to your model and where you can get licensed on a schedule that works for your launch plans.

 

Zoning and Lease:  Check with the local planning department to make sure the location that you are considering is properly zoned for the proposed activity.  If it is not properly zoned, the process to obtain an exception can be long, expensive and unpredictable, so proceed with caution.  If you must enter a lease before applying for an alcoholic beverage license, be sure to include a provision that allows you to vacate the lease if you are unable to obtain the desired alcoholic beverage license at the location.

 

Limited Availability: In some localities and for some license types, the number of available licenses is limited.  If you cannot obtain a new license from the alcohol regulatory agency and have to buy one on the open market, prices may vary widely depending on supply and demand. This is particularly common in densely populated areas.  Be aware that a slight change in location can have a large impact on the availability and cost of the license you need.

 

Consideration Points: Though each state is different, most states do not want alcohol businesses to be close (within 500 ft.) to churches or schools.  If there are residential neighbors near your proposed location, they will also be given an opportunity to oppose your license application.  Try to determine if your business will be welcomed by the local police department and residents.  If local law enforcement does not support your project, you may face an uphill licensing battle.  Moreover, sometimes an active anti-alcohol neighborhood group can delay or even derail a licensing project. Typically, a large poster-sized notice announcing your application will be posted while the license is pending, so if you elect to license your home, be prepared for curious neighbors.

 

The most important consideration in choosing a location for your business is deciding where you want/need to be located.  For example, where do you want to spend your time? Where do you want to make most of your sales?  Do you need to have access to a warehouse or will an office suffice?  What sort of staffing will you need to operate the business and is it available within the local labor pool?  Are economies of scale possible by sharing warehousing or production facilities? 

 

Contact one of the attorneys at Strike & Techel if you have questions about things to consider when choosing a location to get started in the alcohol beverage business.

Imbiblog is published for general informational purposes only and is not intended as legal advice. Copyright © 2013 · All Rights Reserved ·