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If you are renewing your manufacturing license, be ready for a new Pennsylvania Liquor Control Board (“PLCB”) required response:
Please provide the total number of gallons of distilled spirits, malt or brewed beverages, or wine (whichever is authorized by your specific license type) manufactured on your licensed premises in the previous calendar year. (Please do not include any amounts produced for you under contract by other manufacturers, if permitted under the Liquor Code for your license type.)
What’s the point of this new PLCB question?
This question likely targets licensees who are exceeding limited distillery or winery production and should convert to a traditional distillery or winery, or conversely, licensees that underproduce. Regarding breweries, it is superfluous, as breweries already must report sales in 31-gallon increments.
In recent years, the cost of retail restaurant liquor licenses has increased significantly, and supply has waned because of the proliferation of grocery and convenience stores utilizing these retail licenses. Retail licenses can cost up to half a million dollars to buy in some counties. However, there is an option to apply for a manufacturer’s license, which allows restaurants to sell and serve other Pennsylvania products so long as they actually make and serve their own products as well. While the Pennsylvania State Police Bureau of Liquor Control Enforcement (“BLCE”) will check that manufacturers sell 2/3 of their own products, this question may help the PLCB flag non-bona fide manufacturers who are abusing the system.
Does my license have annual production limits, and if so, what are they?
| License Type: | Minimum | Maximum |
| Brewery (G) | 200 Gallons |
None
|
| Brewpub (GP) | 250 Brewer’s Barrels | None |
| Brewery (G) coupled with a Restaurant (R) | 250 Brewer’s Barrels | None |
| Distillery | None | None |
| Limited Distillery | None | 100,000 Gallons |
| Limited Winery | 200 Gallons | 200,000 Gallons |
Which manufacturing licensees must answer the new production question?
The question appears on manufacturing license renewal applications and asks for the production authorized by the specific license type. Licensees should review their renewal application carefully to determine whether the question applies to their brewery, brewpub, distillery, limited distillery, winery, or limited winery license.
What production period should I use?
The question asks for the total number of gallons manufactured on the licensed premises during the previous calendar year. So for renewal applications this year, you would provide your production in gallons for the year 2025
Should I include products made for me by another manufacturer?
No. The PLCB’s question specifically states that licensees should not include amounts produced for them under contract by other manufacturers, where those arrangements are permitted for the applicable license type.
Must my reported production fall within a minimum or maximum?
It depends on the license type. Breweries, brewpubs, and limited wineries have minimum production requirements, while limited distilleries and limited wineries have maximum production limits. Licensees should compare their reported total with the limits applicable to their specific license.
Should a distillery report proof gallons or total gallons of finished products?
The Liquor Code does not clearly answer this question. A distillery or limited distillery may want its response to match its federal excise tax report, which reports production in proof gallons rather than total production volume.
Why does the PLCB want this information?
The response may help the PLCB identify limited distilleries or wineries that exceed their production limits, manufacturers that do not meet applicable minimums, and businesses that may not be operating as bona fide manufacturers.
