Non-Beverage Alcohol Exemption
30 day processing time
What is non-beverage alcohol?
If a substance contains liquor and also contains ingredients that make the substance unsuitable for use as a beverage, a person may, subject to the Act, sell, supply, purchase or use the substance for its intended purpose without a licence or permit. These products contain enough other ingredients or are “denatured” by the addition of substances to prevent them from being consumed as alcoholic beverages. Products denatured using salt must contain a minimum of 1.5% salt per 100 g to be eligible for exemption. The general manager may require that a certificate of an analysis, under section 70 of the Act, be prepared respecting a sample of the substance.
Non-beverage alcohol includes:
- Medicinal products such as cough medicines, stomach bitters, ethnic medicines, herbal liqueurs and remedies, digestive aids, tinctures and tonics;
- Toiletry products such as mouthwash and hand cleansers and;
- Culinary products such as cooking wines, cooking sherries, vanilla extract, and gelled and peppered baking extracts
When to get an exemption
Products that have a greater potential for abuse as an alcoholic beverage – salted culinary products (including cooking wine) and potable (fit to drink) alcoholic preparations -- cannot be sold or distributed in British Columbia without an application to the branch. Most non-potable medicinal products, unsalted culinary products, and toiletries are automatically exempt, but if there is any doubt, an application should be made to the branch.
It is important to note that receiving an exemption from the Liquor Control and Licensing Branch does not remove responsibility from a manufacturer or importer to obtain any other approval, permission, licence or similar requirement by any other authority.
Illegal non-beverage alcohol
The sale or distribution of rice alcohol (or cooking wine made from rice alcohol and with an alcohol content of 10% or greater) is specifically prohibited due to a history of illegal sale and consumption. Only B.C. government liquor stores are permitted to sell rice alcohol. The one exception to this rule is for large-volume commercial sales in containers of 10 L or more, provided they are pre-sold to manufacturers or other commercial users prior to importation into British Columbia.
How to apply
To apply for an exemption for a specific non-beverage alcohol product, applicants must send the following to the Liquor Control and Licensing Branch:
- A letter of application (from the applicant or an authorized agent or customs broker) with the applicant’s business name, address, e-mail, telephone and fax numbers, clearly describing the product, its intended use and the container sizes the applicant intends to make or import;
- Sample labels (front and back) for each container size; and
- Two samples of the product, if the product is not denatured using salt, for the purposes of taste testing.
Labels must contain the following information, in English:
- Brand name (e.g. Tosca, Vicks, Harry’s);
- Name/type of product (e.g. cooking sherry, cough medicine, stomach bitters);
- Container size (in ml, cl, or litres);
- Alcohol content (percentage by volume);
- Manufacturer and/or bottler; and
- Country of origin.
If salt is used as the denaturing agent labels must also provide information on salt content (grams/100 ml).
The applicant must also ensure that the branch is provided with a report from an independent laboratory which must state the alcohol content and salt content if the product is denatured using salt. All products applying for exemption need to provide a lab report on alcohol content.