IDENTIFICATION OF MANUFACTURER ON PACKAGES OF TOBACCO PRODUCTS
Manufacturers of tobacco products:
Purpose. The purpose of this industry circular is to furnish you informa-
tion relative to identification of the manufacturer on packages of tobacco
products as required by regulations in 26 CFR Part 270, effective October 1, 1961.
Background. The regulations (26 CFR 270.212) continue the requirement for
marking of packages with either (1) the name of the manufacturer and the location
of his factory from which the product is removed subject to tax, or (2) the per-
mit number of the factory from which the product is removed subject to tax.
However, where tobacco products are transferred "in bond" between factories of
the same ownership, it is not always possible for the manufacturer to know, at
the time of production, from which of his factories the product will be removed
subject to tax. Accordingly, section 270.212 includes the proviso that the
Director, Alcohol and Tobacco Tax Division, may on application authorize a
manufacturer to mark his packages of tobacco products (manufactured in and
removed subject to tax from any of his factories) with only the name of the
manufacturer if the factory of production is identified by a statement
(e.g., manufactured in Richmond, Va.), by a symbol, or by other means (other
than the permit number) approved by the Director.
Suggestions for Mark on Packages. Where a manufacturer makes transfers
"in bond," and does not wish to mark his packages with the location or permit
number of the factory from which the tobacco products are to be removed subject
to tax, he may comply with the proviso of section 270.212 in any one of the
following ways: To identify the factory of production, a symbol may be imprinted
on the closure, if any, or on the package at the time it passes through the
packaging machinery. As another illustration, the factory of production may be
identified by a statement, such as "manufactured in Richmond, Va.," imprinted
directly on the package, on the closure, if any, or on a label affixed to the
package. Where identification of the factory of production is accomplished
during the packaging operation, identical packaging material can be employed
at any of the factories under the same ownership.
Packages marked in any of these ways can be removed subject to tax from
the factory of production or transferred "in bond" between factories of the
same ownership and subsequently removed subject to tax. Please remember that
there must be a specific application (under section 270.212) to use any of
Inquiries. Inquiries in regard to this industry circular should refer to
its number and be addressed to the office of your assistant regional commis-
sioner (alcohol and tobacco tax).
Dwight E. Avis
Director, Alcohol and Tobacco Tax Division