Alternating proprietorship and contract manufacturing in Connecticut

Each manufacturer must have sole control over the premises during the manufacturing process and sole control over the storage area for their products. In other words, two manufacturers cannot be making products at the same time or store products in the same space.

Each manufacturer must separately own its own ingredients, packing supplies, and raw materials needed to manufacture and can/bottle its products.  All supplies must be clearly labeled as to which manufacturer owns them. 

The manufacturers may buy supplies from each other, but everything should then be inventory and appropriately labeled. 

Each manufacturer owns the alcoholic beverages it produces until those beverages are removed from the premises (e.g., moved to different storage, sold to a wholesaler or sold to a retailer).  All beverages must be clearly labeled as to which manufacturer owns them during the entire manufacturing, bottling, and storing process. 

Each manufacturer should have their own employees, although one manufacturer can pay another manufacturer for the use of their employees’ labor.  

Each manufacturer must maintain its own production records, sales records, state and federal licensing, tax reports, etc. Each manufacturer is responsible for its own taxes.  Each manufacturer needs a federal permit from TTB, the appropriate CT manufacturing permit, COLAs from TTB, and brand registrations from CT. 

No manufacturer may own any part of another manufacturer with which it shares an alternating proprietorship, unless the manufacturers are producing different classes of alcohol.  

Records subject to inspection by Liquor Control.  

A primary manufacturer can only produce an alcoholic beverage for the holder of select Connecticut permits: other manufacturer permits, wholesaler permits, or out-of-state shipper permits. 

The primary manufacturer must maintain exclusive control and possession of the premises used to produce the alcoholic beverage; the other permit holder cannot do the manufacturing themselves at the primary manufacturer’s premises (for that arrangement, see alternating proprietorship, above) or by using the primary manufacturer’s permit as their own.  

The primary manufacturer bears all the responsibility for production of the alcoholic beverage for the other permit holder. 

The label of any product made by the primary manufacturer for the other permit holder must include the primary manufacturer’s business name and address.  

The primary manufacturer must own all the ingredients, packing supplies, machinery, and raw materials used to make the alcoholic beverage. 

The primary manufacturer owns the alcoholic beverage it produces until it is removed from the permit premises (e.g., moved to the other permit holder’s storage, sold to a wholesaler, or sold to a retailer). 

The primary manufacturer must maintain production records of all alcoholic beverages it makes for the other permit holder and pay all taxes due (although it may require the other permit holder to reimburse those costs). 

The primary manufacturer shall obtain a COLA and any necessary brand registration.  

The primary manufacturer cannot sell at retail for off-premises consumption or at wholesale any alcoholic beverage it makes for another permit holder if a wholesaler has distribution rights to that beverage. 

Records subject to inspection by Liquor Control.