REVISION OF FORMS 2637 AND 2733
Proprietors of distilled spirits plants,
and others concerned:
The purpose of this circular is to inform you of an ATF Procedure published in the June Alcohol, Tobacco and Firearms Bulletin.
This procedure changes the categories of rectified whiskies required
to be reported by bottlers of distilled spirits and provides new instructions for preparing Forms 2637 and 2733 which are revised effective July 1, 1973. The procedure reads substantially as follows:
ATF Proc. 73-2
SECTION 1. PURPOSE.
This procedure is to announce that the Director has determined
that, for statistical purposes, a further breakdown of rectified whiskies should be reported by proprietors of distilled
spirits plant bottling premises. Accordingly, Form 2637, Bottling Tank Report, and Form 2733,, Monthly Report of Bottling
Premises Operations, have been revised.
Sec. 2. BACKGROUND.
For several years categories of rectified whisky which proprietors of distilled spirits plants were required to report
have remained unchanged. These categories as reported on
Forms 2637 and 2733 are "Blends of whiskies four years old
and older," "Spirit whisky," and "Other blended whisky". Appropriate footnotes on each form provide a basis for classifying blended whisky into one of these three categories.
Since July 1, 1972, the bottling of light whisky and light
whisky products has been permitted. One effect has been
the establishment of two new types of rectified whisky;
light whisky (with 2 1/2 percent or less blending material);
and blended light whisky (blended with less than 20 percent
straight whisky). In addition, light whisky is being used
in the production of blended whisky in place of neutral
spirits. Consequently, current bottling statistics as reported on
Form 2733 are distorted since whisky products currently bottled no
longer fit into one of the three existing categories for rectified
whiskies. The Bureau is receiving numerous incomplete or inaccurate
Forms 2733, especially with respect to rectified whisky products.
A further reason for changing the reported categories of whisky
is to create categories which adhere closely to the F.A.A. Act standards
of identity. The use of these standards will eliminate confusion
over the identity of each product and will be more easily understood
by the public since the F.A.A. Act standards of identity are reflected
on the product labels.
Sec. 3. CATEGORIES OF RECTIFIED WHISKY.
The revised Forms 2637 and 2733 will provide entries for reporting
four categories of blended whiskies. These are named and explained in
.01 Blends of straight whisky four years old or older.
These are blends consisting solely of straight
whiskies all of which are at least four years old,
containing no neutral spirits. This also includes
blends rectified but exempt from tax under 26 CFR
201.444. The corresponding F.A.A. Act standard is
found at 27 CFR 5.22(b)(5)
.02 Blended whisky blended with neutral spirits.
This represents blended whisky composed of at least
20 percent straight whisky blended with any quantity
of neutral spirits. In addition to neutral spirits,
other whisky, including light whisky, may be included.
.03 Blended light whisky.
This represents light whisky blended with less than
20 percent straight whisky, containing no neutral
spirits. This category does not include light whisky
merely mixed with up to 2 1/2 percent blending material but without additional straight whisky.
.04 Other blended whisky.
This represents all other blends of whisky without
neutral spirits including blends made with straight
whisky and other whisky including light whisky.
Whisky mingled under the provisions of 26 CFR
201.444a is not included since this is considered
an unrectified product.
Sec. 4. FORM 2637.
.01 Form 2637 is being revised to provide proprietors with
necessary data to prepare monthly reports containing
the revised categories of rectified whiskies. Footnote
1 will instruct proprietors to use the designation for
one of the four types of rectified whiskies outlined in
sec. 3 and will provide a brief explanation of each
type. These new categories are to be used in filling
out item 3B, "Kind of product". Also, if light whisky
is bottled, proprietors should note at item 3B whether
it is a rectified or unrectified product.
.02 The June 1973 revision of Form 2637 should be used
beginning July 1, 1973. However, proprietors of
bottling premises may use existing stocks of the
4-72 revision if they follow the instructions contained in footnote 1 of the 6-73 revision when next
reprinting Form 2637.
Sec. 5. FORM 2733.
.01 Part III, Summary by kinds, of Form 2733 is being revised to show the new types of rectified whiskies.
Line 2 will be entitled "Blended Whisky" and will
have entries as follows: Line 2(a) "Straight whiskies"
described in sec. 3.01; Line 2 b "With neutral spirits"
described in sec. 3.02; Line 2 c "Blended light" described in sec 3.03; and Line 2 d "Other" as described
in sec. 3.04. These types correspond to those to be
reported on Form 2637 on and after July 1, 1973.
.02 The June 1973 revision of Form 2733 contains three
lines for total whisky. These are: Line 3, "Imported
whisky"; Line 4, "Domestic whisky distilled at 160°
and under"; and Line 5, "Domestic whisky distilled at
.03 Light whisky should be reported on Line 5 of Part III,
in column (j) if bottled without rectification and in
column (k) if mixed with 2 1/2 percent or less blending
material. Blended light whisky should be reported at
Line 2(c), column (k).
.04 Do not add the quantities of Line 2(a), (b), (c), or
(d) in the total for column (k). These quantities of
rectified whiskies should be included in column (k)
of Lines 3, 4, and 5 for total whisky as follows:
1. Line 3, column (k), "Imported whisky," should
include any blends composed of imported whiskies
which are reported on Line 2(d), plus any additional rectified imported whiskies except those
exempt from tax under 26 CFR 201.444a.
2. Line 4, column (k), "Domestic whisky distilled
at 160° and under," should include any blends
reported at Line 2(a) or 2(b), any blends of
domestic whisky reported at Line 2(d), plus
any additional rectified domestic whisky distilled at 160° and under. Do not include blends
exempt from tax under 26 CFR 201.444a.
3. Line 5, column (k), "Domestic whisky distilled at
over 160°," should include the quantity of blended
light whisky reported on Line 2(c) plus any other
rectified domestic whisky distilled at over 160°,
including rectified light whisky. Do not include
blends exempt from tax under 26 CFR 201.444a.
.05 The June 1973 revision of Form 2733 should be used beginning with the monthly report for July 1973. Dispose of
all prior revisions of this form at this time.
Sec. 6. EFFECTIVE DATE.
See sec.4.02 and 5.05 for the effective date for use of the June
1973 revisions of Forms 2637 and 2733, respectively. Prior revisions
of Form 2637 may continue to be used after that time if the instructions
in revised footnote 1 of the 6-73 revision are followed.
Inquiries regarding this industry circular should refer to its
number and be referred to the office of your regional director.
Rex D. Davis