MANUFACTURE AND USE OF PLASTIC CONTAINERS
Proprietors of Distilled Spirits Plants, Importers,
and Others Concerned:
Purpose. This circular is to advise industry members that an
ATP Procedure regarding the possible use of plastic containers for
bottling distilled spirits will be published soon in the ATF Bul-
letin. The procedure will read substantially as follows:
Section 1. PURPOSE.
This ATF Procedure sets forth the position of the
Bureau of Alcohol, Tobacco and Firearms (ATF) with regard
to the possible use of plastic containers for bottling
distilled spirits and provides procedural guidelines for
Sec. 2. BACKGROUND.
.01 The concept of utilizing plastic for manufac-
turing liquor bottles is not new. Several years ago an
experimental packaging and marketing program was authorized
for distilled spirits plant proprietors who proposed to
bottle distilled spirits in polyvinyl chloride (PVC)
plastic bottles. The experimental program was terminated,
however, on May 11, 1973 (Industry Circular 73-10), as a
result of a Food and Drug Administration (FDA) proposal
that PVC resin not be used as a component of food pack-
aging material where such material would come in contact
with alcoholic foods. Since that time, there has been
no authorization given to package distilled spirits in
plastic containers of any kind.
.02 ATF is aware of a renewed interest on the part
of the distilled spirits industry regarding the develop-
ment and acceptability of a plastic liquor bottle. Over
the past few years, plastics technology has progressed
to the point that plastic barrier resins other than PVC
may now be capable of meeting FDA requirements for
alcoholic beverage packaging. It is conceivable, there-
fore, that rigid or semirigid containers manufactured
with one or more of these plastic resins may ultimately be
considered feasible by the industry for packaging distilled
Sec. 3. PRIMARY CONSIDERATIONS.
.01 No action will be taken by the Bureau with regard
to industry applications for the use of plastic liquor bot-
tles until the following conditions and considerations have
been appropriately taken into account:
1. Bottle Specifications
(a) Bottles must be rigid or semirigid, i.e.,
having a molded shape or design which cannot be per-
manently altered by pressure without damage to the
(b) The plastic compound must be approved by the
Food and Drug Administration for use in containers for
packaging alcoholic beverage products for human con-
sumption. Written verification from FDA will be
required to assure that the plastic formulation meets
all applicable FDA requirements.
(c) Bottles must be manufactured only in approved
2. Laboratory Tests
The ATF laboratory will conduct tests of plastic
bottles regarding their suitability for packaging
distilled spirits. These tests will take into consid-
eration proof gain or loss, volume reduction, and other
3. Environmental Assessments
Under the National Environmental Policy Act of
1969, we are required to consider the environmental
impacts of any major action taken by the Bureau. In
addition to the Environmental Impact Statement which
was issued regarding the proposed PVC liquor bottles,
there will be a need for further studies into the
environmental aspects of other plastics prior to our
taking any action regarding their proposed use in the
manufacture of liquor bottles. Environmental Impact
Statements pertaining to liquor bottles proposed to be manufactured with other plastic formulations may
have to be prepared and issued before a decision can
Sec. 4. BUREAU PROCEDURE.
.01 Preliminary Testing Program.
The Bureau has no objec-
tion to the experimental use of plastic liquor bottles for shelf
testing, organoleptic research, or other applicable tests con-
ducted under laboratory conditions. Such tests shall utilize
samples withdrawn in accordance with 27 CFR Part 201 and may not
involve distribution of distilled spirits packaged in plastic
containers to consumers in any way. Test results may be provided
to the Bureau to assist the ATF laboratory in its analysis of
the plastic material.
.02 Application for Approval.
Any authorized bottler or
importer desirous of seeking permanent approval to package dis-
tilled spirits in plastic containers for distribution will be
required to submit a formal letter application to the Director.
Verification must be provided with this application that the
plastic compound in question meets all applicable FDA require-
ments for alcoholic beverage packaging. Any extractive and
toxicity data received in support of this verification will be
subject to confirmation by the Food and Drug Administration.
Applicants should also furnish any available environmental
information regarding the plastic formulation to the Bureau as
an aid in the preparation of any Environmental Assessments that
may have to be prepared. This information may be submitted with,
or at any time prior to, the formal application.
Samples of plastic containers shall be made
available to the Bureau before an application may be considered.
Such samples may be submitted with the formal application or in
conjunction with any preliminary testing program. The samples
submitted should include at least six empty plastic bottles of
each size to be used, two filled plastic bottles of each dis-
tilled spirits product and two filled glass bottles of each
product for purposes of control and comparison.
.04 Final Action.
We anticipate that satisfying the fore-
going requirements will be a time-consuming task. Therefore, we
feel that a final decision on any formal application could not be
made in the near future.
Inquiries. Inquiries concerning this circular should refer to its
number and be addressed to the Assistant Director, Regulatory Enforce-
ment, Bureau of Alcohol, Tobacco and Firearms, 1200 Pennsylvania
Avenue, NW., Washington, DC 20226.
Rex D. Davis