Hello, first, apologies for English—my Dutch is not great. If you reply in Dutch, it's no problem though.

 

I am in the early stages of forming a company for importing some small-batch liquors from outside of the EU. I've done quite a bit of research on the import process, taxes, who I can sell to (only businesses), and the like (informed in large part to this helpful article). I'm now left with a few questions:

1. I am probably going to import bulk containers. If so, that would mean that I would have to rebottle and label the liquor. I've read SpiritsNL's information on labeling. If I follow the rules there am I good to go or is it necessary for the label to be reviewed by some authority? Anything else to be aware of?
2. Regarding rebottling, I am not able to find much, but perhaps I haven't been looking in the right places. All I can find are rules around container sizes. Does rebottling have to be done in a special facility?
3. Last, but not least, I am trying to make sure I understand the risks of this. Of course one hopes nothing goes wrong, but hope alone isn't enough. I understand that as the importer I am legally viewed as the producer in the EU and therefore assume any product liability. So, I am curious what the best way(s) to reduce risk would be. I have thought of testing samples from the batches as well as taking out product liability insurance, but am unsure how practical and comprehensive this would be. Any advice?

 

Thank you for reading and the advice!

Welcome to the HL-Forum

 

Maybe you will find some extra information HERE

Thank you. Yes, I have spent a good amount of time on the site you linked. 

 

For what it's worth, I have done some research already, including going to the KVK to speak to an advisor, searching on this forum (e.g., this thread, this thread, and here to learn about liability). So I'm not going into this completely naively :) 

40 minuten geleden, cabra_123 zei:

So I'm not going into this completely naively

So I noticed...

Hopefully there will be some more answers here by participating members 

Op 4-4-2023 om 09:47, cabra_123 zei:

 

1. Regarding rebottling, I am not able to find much, but perhaps I haven't been looking in the right places. All I can find are rules around container sizes. Does rebottling have to be done in a special facility?

 

Do you want to do the bottling yourself or do you want to rent a filling line for bottling?

 

If you want to rent a filling line, you can ask breweries if they do 3rd party bottling. I know from my own experience that many breweries do not do their own bottling but instead rent a line from a competitor. Also some small breweries do bottling for 3rd parties and there are also companies specialized in bottling for 3rd parties. 

 

https://www.koningsdrinks.com/packaging-solutions

https://swinkelsfamilybrewers.com/nl/contact.html

https://www.refresco.nl/nl/wat-we-doen

23 minutes ago, Derek-Jan said:

 

Do you want to do the bottling yourself or do you want to rent a filling line for bottling?

 

If you want to rent a filling line, you can ask breweries if they do 3rd party bottling. I know from my own experience that many breweries do not do their own bottling but instead rent a line from a competitor. Also some small breweries do bottling for 3rd parties and there are also companies specialized in bottling for 3rd parties. 

 

https://www.koningsdrinks.com/packaging-solutions

https://swinkelsfamilybrewers.com/nl/contact.html

https://www.refresco.nl/nl/wat-we-doen

 

Thank you, this is very helpful. Initially the scale will be such that renting a line probably wouldn't make sense, since I assume it's only on the order of thousands of bottles that it becomes profitable. But I'll reach out to these people to learn more and confirm (or not) my assumption. And it's good to know for the future.

 

I think for up to a few hundred bottles, I can do it myself, assuming it's allowed. For example, if you wanted to, could you do the bottling in your home kitchen? Obviously it must be clean and sanitary, but aside from that are there rules around this?

10 minuten geleden, cabra_123 zei:

 

Thank you, this is very helpful. Initially the scale will be such that renting a line probably wouldn't make sense, since I assume it's only on the order of thousands of bottles that it becomes profitable. But I'll reach out to these people to learn more and confirm (or not) my assumption. And it's good to know for the future.

 

I think for up to a few hundred bottles, I can do it myself, assuming it's allowed. For example, if you wanted to, could you do the bottling in your home kitchen? Obviously it must be clean and sanitary, but aside from that are there rules around this?

 

If you import per tankcontainer you talk about 25000 liters. Or what did you have in mind?

41 minutes ago, Derek-Jan said:

 

If you import per tankcontainer you talk about 25000 liters. Or what did you have in mind?

Oh, much smaller. On the scale of barrels—these are small batch liquors. 

5 april 20232 j aangepast door cabra_123

11 minuten geleden, cabra_123 zei:

Oh, much smaller. On the scale of barrels—these are small batch liquors. 

 

Ok, as you said "bulkcontainers" i thought about the 25000ltr containers, so thats why i came up with those ideas about renting a line. 

33 minutes ago, Derek-Jan said:

 

Ok, as you said "bulkcontainers" i thought about the 25000ltr containers, so thats why i came up with those ideas about renting a line. 

 

Apologies. By bulk I meant "not packaged for retail." They are ~100 liter containers.