Discussion in 'US - Pacific' started by ModernTimesJacob, Feb 13, 2013.
I thought that was Ken Weaver.
Ken does do a lot of good stuff, too. And you are right in that Joe didn't found the site, but he does own and run it.
You gonna get banned, son.
Not according to the TTB :
Even in those states that consider growler filling "bottling" and requires labeling for growlers, I can't believe ANY state insists on pre-printed silk-screened branded growlers - only labels with the required state and federal information, just as every bottled beer with paper labels is so packaged.
There is probably no legal reason that every brewer in other states can't offer adhesive labels (even charging 50¢ or some token amount to cover the printing cost) on blank or others' growlers, rather than insisting on "thier" growlers. Note that California ABC is not changing their growler labeling rules, but simply explaining them.
I'm not sure what we'll be doing at The Bruery, but here's some issues that come to mind as to why a brewery would not adopt this method:
-- One size fits all label. Growlers vary dramatically, as does the same growler type from different breweries. The labels will generally have to be made to fit the smallest area on most growlers to work. If the information from the original brewery growler needs to be covered up beyond what the new label covers, then there are going to be some annoyances with having to put stickers over that information.
-- Growler sealing. Every brewery should be sealing growlers so as to create proof of being a sealed vessel so that customers are not accused of driving around with an open container. Growlers vary in how they are sealed, so breweries are going to have to be prepared on sealing different types of growlers. We use zip ties on our growlers, so other breweries would need to be prepared to have these or something similar to seal our growlers. We don't have a shrink wrap gun for sealing screw top growlers, but we might have to get one if we were to fill them.
-- 64 oz. growler versus 2 L growler. There's a size difference between these two growlers of 3.7 oz., and breweries will need to have two different labels for this (and two different label approvals per brand as well).
-- Breweries often choose growlers that they believe will protect their beer in the most effective way. We choose the swing top growler as the gasket leaks / lets out Co2 far less than the screw top variety. I personally feel that filling screw top growlers could potentially compromise the beer, especially for folks who ship growlers (not something we really want to see, but it happens) or those who hold on to growlers for beyond the recommended period of time.
-- Sticker removal. Let's say someone has been using a Bruery growler at other places, so it's covered in waterlogged paper stickers and they bring it back to The Bruery to get a fill. Our staff will either have to clean off all of the stickers (a time consuming task), reject our own growler (hopefully not, but I could see it happening), or put another sticker on top of our own growler (most likely solution). This sloppy look will not be attractive to many breweries trying to build a good reputation for cleanliness / good branding.
-- Logistics of filling growlers. What if the growler doesn't fit well under our taps? What if a certain type of growler causes more foaming / beer loss than the growler that brewery is accustomed to? Our fill tubes are for our growler size, so I could see some issues with shorter or taller growlers filling equally as well as ours does. Also, there are a few different products on the market for growler filling that'll work under counter-pressure to allow for Co2 purge of growlers, more carbonation, and less waste. If a brewery invests several thousand dollars to get one of these contraptions, they will only be able to adequately fill one growler size.
-- Different sized growlers (1L, 32 oz., etc.). Labels will have to reflect this size difference, and I believe they'll all have to be separately approved by ABC. For example, if we wanted to accommodate most potential sizes for Humulus Lager, we'd have to submit a separate label for 32 oz., 1L (33.8 oz.), 64 oz., 2L (67.7 oz.). Multiply that by the 8-10 growler fills we offer, and keep in mind we have a few new beers each month to register. Also, having to price beers on a per oz. basis is quite different than most breweries currently price growlers. We have our growlers entered into our point of sale system, so imagine we have 4 different pricing structures depending on what kind of growler we're filling. How do we communicate this range of prices to our customers?
-- Loss of revenue on empty growler sales. Plenty of breweries count on a steady revenue stream from the sale of empty growlers. I imagine this will be reduced if any growler could be filled. Many breweries sell growlers close to cost, so this certainly isn't a universal excuse.
Sorry to be pessimistic, but I hope this helps add some context. I'm sure there's plenty of places that will offer this, but I hope you'll understand why some breweries won't be allowing this. It's going to be a mess. If we allow it, we'll likely have some standards on what we'll fill and what we won't.
A nice post, but I wanted to respond to several of your concerns:
Several of those are redundant.
Every. Single. One. of these concerns can be addressed by having a posted policy:
"- We will only fill blank or Bruery-branded 66 oz gasket swing tops" (with photo of example)
"- Please clean your growler (including stickers) before bringing it in"
Not to jump to conclusions, but at the cost of your glasses ($10?), I imagine this is the biggest concern for you, and most other breweries.
But yes, I certainly understand why it won't be an overnight change as far as logistics and branding goes.
I definitely see your point. Already existing breweries you have become accustomed to the current growlers would/may possibly see a dip in empty growler sales, but I also see breweries also now being able to charge more for growler fills on the different glass/growler types that would be brought in. An example of this would be in Oregon at Block 15, they do counter pressure their own 32ounce growlers but fill any other type of glass. They don't have a special setup, but they also dont base a lot of their sales off of empty growlers like California breweries do. I definitely understand that most California breweries are able to profit more from empty growlers, because of the California growler practices; in my opinion this stipulation has allowed breweries to make more profit instead of just making profit on the beer alone.
With this clarification we will hopefully see breweries allowing customers to fill more non-brewery growlers. I personally have over 35 growlers because of the CA Growler laws, but now with just a label covering a blank glass growler, and also that can cover the other breweries label, I can now bring 1 or all of them to possibly any CA brewery and get them filled up. But I definitely understand if a lot of breweries are hesitant to start stickering growlers, but if other states dont have a problem with doing that I dont see why CA Breweries would. I am not saying that we should start filling 64ounce mason jars, like some OR breweries do, but I think this would definitely increase growler fill sales instead of sales now based on empty growlers. I know I am not in the minority when sometimes I go to a brewery and want to get several growler fills but cant because I have to purchased several establishment labeled growlers, which then deters me from buying any beer. So, I hope to see some change, but I can understand if some breweries dont want to let go of empty growler sales versus filled growler sales, time will tell.
I think this is a naive argument.
Given how much you make on a growler fill, how many times would someone have to fill a non-Bruery growler at your establishment before you broke even? I imagine not that many. And I also suspect that there are lots of people out there like me who would start getting a lot more growler fills if they could use a blank one (and even more if it were 32oz/1L, but that's another battle).
Most of the arguments you cite are arguments for the CA law as it was previously interpreted. But plenty of other states manage to fill other breweries' growlers without major problems. I don't quite understand the ones that are unique to the new interpretation which just allows for putting adhesive labels on a growler; when I get a growler filled, someone just writes what the beer is on the cap. They're getting label approval for that?
As I said before, people need to wait while breweries digest this news. The next Brewer's Guild meeting for San Diego is in 3 weeks...I'm sure this will be a lively discussion as each individual brewery figures out what they plan to do.
All of 'em may not be on board, so I'm sure lists will be generated of which breweries will fill any growler, and others that'll have their own policy. Which will generate lots of more threads of bitching & moaning. However...we're not there yet. Hell I bet a good number of breweries are still unaware of the clarification of the law. The ABC needs to push that out.
Until then...keep your panties from twisting too tight.
I see an increase in business for the breweries that will fill other growlers.
Exactly, as I stated earlier I would fill growlers much more often if I could do so without purchasing yet another branded one.
If I walked into the Bruery tomorrow, I know that I would not buy one of their branded growlers. If I did, it would be used once, and then sit in my cupboard with the 5 or 6 other rarely used ones that I already have.
Unfortunately, branded growlers only seem to make sense for people who are regular customers. (or those that like to collect them.)
It's unfortunate that a lot of breweries are probably going to take the stance of, "We'll this is just too much work for us, so we won't do it."
Really, they have more to gain by complying. I imagine the number of people who come n for fills will skyrocket.
I do too, and that in turn may cause other's to re-evaulate their position. Having been to boneyard in Bend, and only being their briefly, they had Sooo many people popping in to fill all size & manner of growlers while I was there, and they are tiny compared to some CA operations. I respect Patricks concerns, but I also agree that many can be overrided by a clear stated, posted, and defined policy on filling other growlers, by size, type. etc. and have this posted online, in the tasting room, etc. As a business, they can have standards, and still be compliant with the new interpretation of the law.
Also, established places like the Bruery (RR, FW, Stone, dozens of others) have many out of state, out of town/city visitors, and if they could for the most part fill any CA growler, seems that would add up in fills, more then filling just their own. I own Bruery growlers, and can just take them there myself, and can continue to use the ones I already own for the places I use them, but I also have stopped buying new growlers as result of the previous interpretation of the law, because after a dozen, it get's silly. Now, hopefully, I can just have a small variety of clean growlers with me in my car to get a fill at the places that will fill them.
Interesting to see Patrick's response.
I figured there would be pushback by the breweries on this, precisely because of the revenue of growlers. I have no doubt they won't be the only place with this concern, and I can see breweries taking an 'our growler only' stance regardless of the ABC ruling. I do know I'd be a hell of a lot more likely to get a growler fill if I had an empty with me, than to buy both the growler and the fill.
Gonna be interesting to see how this plays out
as is the case with most, I know I would be compelled to buy WAY more growler fills at breweries if they wised up and adopted this interpretation of the law. I easily have 15 empty growlers at my house (and I'm sure others have far more) and I don't need another one. Having to get yet another growler is huge detractor in deciding whether to buy a growler fill at a brewery these days. It's a space issue and it's just flat out wasteful. If breweries take this stance...shame on you.
If I owned a brewery I would have someone in marketing all over this. I would have labels printed with something like "another awesome fill from Hosers Brewery". I would advertise how we are going green by reducing the amount of resources used to make glass. I would tell everyone that I was looking at providing great craft beer at the lowest cost possible. Maybe say if you use our branded glass you get $1 off the fill, but we will happily fill any growler. Might even have a once a week or once a month special where we fill someone else's glass with our beer at a discount (increase traffic on slow days/times) with the purchase of a pint.
Gotta think ahead and make the first move.
For brewers reading this thread, here is what this beer geek thinks would work best.
Policy: "We will only fill our own branded growlers -OR- blank & clean 1 or 2 liter swingtop growlers"
The standard 1 and 2 liter growlers can be found at any homebrew shop for about $5 and $12 respectively.
Price: If somebody brought in a blank 750ml or 32oz swingtop, you fill it for the 1 liter price. If somebody brings in a 64oz or any other size less than 2l but more than 1l you charge the 2liter price.
Label: Something as simple as this hang tag with the brewery information printed on it. I think we all can agree hang tags on blank growlers is a lot easier than stickers and will cost next to nothing.
Patrick, I have been to The Bruery tasting room a couple of times and have not purchased a growler, I would have absolutely filled my blank growlers that I already own through homebrewing. Consider guys like me making up for some of the lost revenue from selling growlers. Also, you could offer blank growlers in your tap room as well.
That's actually a great idea. Still gives people a reason to buy your glass if they're local, but doesn't lock out non-locals who don't want yet another useless piece of glass. Kern River does (did?) a similar thing with their six-bottle holder, I'm sure they sold a good number of those.
This is exactly what I was thinking. And if you use zip-ties it (hopefully?) solves the sealed-container issue that Patrick brought up.
Every place I've been to recently just throws some tape around the top (RR actually only started doing this recently, I'm not sure why they weren't doing it before). I think PMR was going a bit overboard there, it's a pretty trivially solvable problem.
You skipped this part:
Under some circumstances, a growler is a glass and not subject to TTB labelling requirements; under others it's a bottle and is subject to the labelling requirements. As usual, they suggest taking the conservative approach and covering your bases. I checked all my growlers, and only one--from a brewery that makes a habit of not following the rules--doesn't have the gov't warning.
That's a hilariously Orwellian approach to language. When a regulatory agency completely changes the way businesses can behave based on a reinterpretation of the code as a result of lobbying from a trade organization, that may not be a change to the code itself, but it is certainly not an explanation. They issued a white paper opinion revising their interpretation of their own rules. That is, for all intents and purposes, a change. Their field officers had been insisting, for years, that breweries could only fill their own growlers, under threat of penalties ranging from $750-$10,000 fine and/or suspension of license. It is not the case that breweries were too dense to understand the rules; it is the case that the ABC changed their rules, even if they didn't revise the code, which would require legislation.
How does The Bruery label the beer name and abv on growlers they fill currently?
I ask about The Bruery, only because Patrick chimed in with the labeling as being a potential hangup on doing blank growler fills.
His hangup was on having the correct label size for 12 different sized vessels and the potential for not being able to cover up a pre-existing silk-screened logo on said vessel, which is required by law. Blank growlers are the easiest way to go and would cause the least amount of issues.
Just imagine the issue with the tickers and all their thimble sized 'growlers'!
64 oz Klean Kanteen.
Been a few months since I got a fill, but the last I got was Berazzled, and it just had a penny sized sticker on the flip top that said "BRZ" on it. Nothing about the abv. Otherwise, their silk screened growlers have their name, address, and the Surgeon General warning of course.
One of the local nano's near me, Enegren, already uses cards they hang from the growler with twine that says the beers name, & abv on it for their two year round beers, and they just write the name and abv on the blank line for their seasonals or one off's. Their growlers have their breweries name on it as well. I would hope they would be open to filling blank growlers, and just use the same method they currently do to identify the contents. They are 2L fliptops.
Enegren is local to me as well, I'm in Simi.
They have been an unfortunate victim of my growler buying hiatus. I have emailed them along with Ladyface and Surf to inform them of the change if they weren't already aware; I will be at Enegren to fill a growler as soon as they start filling blank ones.
Once this takes hold what am I gonna do with 2 dozen screw cap growlers? shooting practice maybe?
Recycle them. Put kegerator in space that growlers were occupying.
Already have two kegerators. Thinking a cave would be a better choice
Yes, I skipped it because the TTB says:
So that by its very definition does not apply to the situation for beer buyers who are concerned with owning too many growlers and/or not having the "correct" one at a brewpub, since their personally-owned growlers brought to the bar are not being "filled ...in advance of sale".
Like everybody else in this thread, I would like nothing more than as many breweries as possible to adopt this policy. But from various breweries' financial perspective, one thing to consider is: how many growlers are filled by the BA/ratebeer crowd, and how many by casual beer drinkers? In other words, how much of the sales presence is represented by hardcore beer geeks like us who are tired of owning a dozen growlers, and how much by casual drinkers who own no growlers and for whom the glassware is a reasonable impulse buy?
It's easy to read this nearly unanimous thread and think the decision a no-brainer, but if they get a whole lot of non-beer geek traffic buying new jugs, I could imagine that the frustrations of a relatively small core of beer nerds may not be a very compelling reason for them to alter their growler policy.
It's not uncommon to find more transplants than locals in Southern California. On many instances I had to explain that we have to use brewery specific growlers for fills to those I came across from areas with much more open and liberal growler filling laws.
I've held back on a few brewery growlers because I'm just too overcrowded with growlers. But count me among the many who will gladly fill up a growler if I could just take any ol' one there.
The whole cost of glass and losing out on glass sales seems silly though. You'll be making up with far more fills. I know I've had instances were I was at ladyface or other no bottled version available beer where I would have gladly taken 2-3 of my growlers. But no way was I going to buy another of the in-house growler and sit on extra empty glass like that.
What makes you think that business would go away for a brewery?
If you're a non-geek and impulse growler buyer, you aren't going to carry blank growlers in the trunk of your car or think to bring a blank with you to get filled in the first place
At that point you should just consider growlers like T-shirts. Merchandise sales to promote your business. But you don't require someone who wants to buy your beer to have to buy a shirt, do you?
It's nice that Patrick made his peace about it and we get to hear from a brewery owner. But considering how very little effort the Bruery puts into labeling what is in the growler currently, how much more difficult would a Bruery black sticker, masking tape and a tag would be?
Like someone else said above. Last time I got a growler fill there, they simply wrote in short hand what beer was in the growler with a circle sticker. No abv or any other info. Hell, adhesive white labels with a bruery stamp would be a better choice. As you can write more info on it and cover other logos.
I'm certainly not saying that side of business would go away; I'm just saying I don't know if the frustrated beer crowd necessarily comprises incentive enough for some breweries to make the change, at least at first. I would like to be proven wrong.
there seem to be many different ways that the new interpretations can be implemented....from stickers to tags...if you arent willing to put any effort into this, then your just going to continue losing growler-fill business. if it's really about the glass sales, then just come out and say that and dont make it your 12th point of contention.
ps. you make some damn tasty beer
I wonder if they just aren't aware of the frustration? I have quite a few friends that enjoy good beer, (they aren't at the geek level I am, member of BA, etc...) but I know they too are growing weary of buying growlers from every place they visit.
His last point of contention was probably his primary contention.
All they need to do is continue selling branded growlers for the casual customer and collector and allow generic growler fills for the BA/ratebeer crowd. They're not getting our business from fills as it is so the loss of revenue from glass is offset by the increase in fills that they'd get from us.
A brewery could also state what they're willing to fill. So that would eliminate all the bizzaro sized containers people might bring in. They just have to set their policy but this is going to be a headache and they can respond to it however they want.
While I do have enough growlers to cover a good 60% of the breweries in existance today, this'll just be a transition period as people change. Breweries will always have new glass on hand for the casual buyer, it hasn't sunk markets like Oregon or whatever, this isn't a deal breaker for the breweries.
Just gotta give it time.
Separate names with a comma.