Industry Circular

Number: 69-20

Date: September 12, 1969

Department of the Treasury

Internal Revenue Service

Alcohol, Tobacco, and Firearms Division

Washington, D.C. 20224

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Experimental Packaging and Marketing of Distilled Spirits in PVC Plastic Liquor Bottles.

Proprietors of Distilled Spirits Plants, Manufacturers of Liquor Bottles, Importers, Wholesale Liquor Dealers, and Others Concerned:

When we published Industry Circular 68-32 in November 1968, we understood that several bottlers were prepared to start the experimental use of polyvinyl chloride plastic liquor bottles early in 1969. On that basis we assumed that by mid-year we would have received sufficient factual data, concerning the performance and adaptability of PVC bottles under actual marketing conditions, as to enable us to determine the suitability of bottles made from such material for continued use for distilled spirits. However, we were over-optimistic in this respect and therefore additional experimenting time will be needed.

We do not yet have sufficient information concerning how the PVC bottles would react to some of the conditions to which they might be exposed in actual marketing situations, where extremes of temperatures and a wide variety of bottling and handling procedures could be encountered before the bottles finally reach consumers. We are, therefore, not yet ready to make a final decision concerning the general use of PVC plastic bottles on a continuing basis.

Accordingly, those proprietors who have been granted authorizations until December 31, 1969, to use polyvinyl chloride plastic liquor bottles may continue such use beyond that date within the limitations of the other conditions specified in their respective letters of authorization. Such ex- tended time shall terminate December 31, 1970. Any proprietors who have not previously been granted such authorization but who would like to engage in the experiment during the remainder of its term (as herein extended to December 31, 1970) may apply for such privilege pursuant to the procedures stated in Industry Circular 68-32. Proprietors whose original authorizations were based on the use of liquor bottles made of calcium zinc stabilized PVC compounds (including propylene modified compounds) may apply for amendment of their authorizations to include or substitute the use of any other PVC formulations now permitted by the Food and Drug Administration.

Ralph H. Alkire, Acting Director

Alcohol, Tobacco and Firearms Division