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Industry Circular

Number: 72-36
Date: November 2, 1972

Department of the Treasury
Internal Revenue Service Alcohol,
Tobacco and Firearms Division
Washington, D.C. 20224


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Proprietors of bonded wine cellars, taxpaid wine bottling houses, importers, and others concerned:

Purpose. The purpose of this circular is to inform you that we are conducting a study of the effects on wine packaged in plastic containers. Such study will necessitate your submission of samples of wine and plastic containers to the Bureau for analysis, if you intend to use plastic containers for packaging or importing wine.

Background. A study was conducted prior to our approval of a trial period for plastic liquor bottles; however, we have no experience or analytical data with respect to plastics as a container for wine. Since there are significant differences in the basic properties of distilled spirits and wine and because of our concern with consumer protection, the Bureau is investigating the possibility of the introduction of materials beyond authorized limitations by the extraction of such materials from container walls.

Submission of Samples and Related Data. Prior to the use of plastic containers for packaging wine or the importation of such, the following should be submitted for appropriate analysis:

1. A statement of composition of the plastic compound to be used including any additives (such as stabilizers or plasticizers) used therein, including the percentage of each, and reference to the particular section and paragraph number of the Food and Drug Administration regulations under which the materials are approved.

2. A 24-ounce sample, or larger, in glass, of wine which has not been in contact with a plastic container.

3. A 24-ounce sample, or larger, of the same wine packaged in a plastic container, with the date of packaging clearly indicated.

4. Six empty plastic containers.

Inquiries and Samples. Inquiries regarding this circular should refer to its number and be addressed to the Director, Bureau of Alcohol, Tobacco and Firearms, Washington, D. C. 20226., Attention ATF:RI. Samples should also be submitted to the Director, but to the Attention of ATF:TSC.

Rex Davis

Rex D. Davis


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