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Rules for making or importing non-beverage alcohol
Unlike beer, wine or spirits, non-beverage alcohol is liquor
that is not intended for drinking.
BC allows a number of non-beverage alcohol products to be produced
and sold here without restriction (these products as "exempted" under Section 62 of the Liquor
Control and Licensing Act).
A variety of other non-beverage alcohol products are exempted,
but must be monitored and/or have their sales regulated by the Liquor Control and Licensing Branch, whether or not
they can be sold in BC. The branch may restrict quantities and/or determine how these products are to be stored,
distributed and sold.
Still other products - usually with a higher amount of alcohol
- may not qualify for exemption under Section 62, and must be distributed through the Liquor
Distribution Branch.
Any manufacturer or importer found selling or buying a non-alcoholic
product not exempted under Section 62 may have the product seized and face a fine of $500.00 or more.
Categories
The Liquor Control and Licensing Branch classifies non-beverage
alcohol as either:
- Non-potable (non-drinkable) alcoholic medicinals
These are cough medicines, medicinal tonics, tinctures, etc.
Most contain enough ingredients other than liquor to stop them being consumed as alcoholic beverages, and manufacturers
or importers of non-portable alcoholic beverages are not normally required to apply for an exemption. However, if
there is any question about whether or not a medicinal preparation containing alcohol satisfies Section 62, manufacturers
and importers should apply to the Liquor Control and Licensing Branch to confirm that they are exempt, before they
start to make or import the product.
- Potable (drinkable) alcoholic medicinals
These include stomach bitters, digestive aids and tonics claiming
to have restorative or therapeutic value. Potable alcoholic medicinals are subject to the Pharmacists,
Pharmacy Operators and Drug Scheduling Act as well as the Liquor
Control and Licensing Act, and may only be sold in pharmacies. Any company planning to make or import these products
for sale in British Columbia must apply to the Liquor Control and Licensing Branch for exemption. The branch will
monitor and regulate the sales of any product that qualifies for exemption.
- Preparations containing alcohol
These are toiletries, such as mouthwash; cooking preparations,
such as vanilla extract and liqueur-filled chocolates; cleaning and disinfecting agents, such as Lysol; baking flavours
and extracts; and "industrial strength" flavouring agents. Most are automatically exempted because they
contain enough ingredients other than liquor to stop them being consumed as alcoholic beverages. However, if there
is any question about whether or not a preparation satisfies Section 62, manufacturers and importers should apply
to the Liquor Control and Licensing Branch to confirm that they are exempt, before they start to make or import the
product.
- Salted culinary preparations
These include cooking wine and cooking spirits, etc. Because
many salted culinary preparations have the potential to be potable unless denatured (made unfit for drinking), any
company planning to make or import these products for sale in British Columbia must apply to the Liquor Control and
Licensing Branch for exemption. The branch will monitor and regulate the sales of any product that qualifies for
exemption.
About cooking wine made from rice alcohol
BC government liquor stores are the only outlets allowed to sell
rice alcohol with a salt content of less than 1.5 per cent.
Private retailers are restricted to selling rice alcohol with
an alcohol content of less than 10 per cent and a salt content of at least 1.5 per cent.
Commercial users (such as restaurants and food manufacturers)
may buy cooking wine made from rice alcohol that contains more than 10 percent alcohol directly from importers or
distributors, in bulk containers of 10 litres or more.
Importers and distributors must pre-sell each shipment, and report
this information to the Liquor Control and Licensing Branch. The reports must cover the entire shipment and be submitted
for each shipment. Importers complete the Record of Cooking
Alcohol Shipment (LCLB46) form; distributors complete the Record of
Distributors' Sales of Cooking Alcohol (LCLB47) form.
Application process
To apply for an exemption for a specific non-beverage alcohol
product, you will need to send to the Liquor Control and Licensing Branch:
- a letter of application (from you or an authorized agent or
customs broker) - with your business name, address, telephone and fax numbers - clearly describing the product,
its intended use and the bottle sizes you intend to make or import
- three sample bottles of the product
- sample labels (front and back or individual carton as applicable)
for each bottle size, and
- if applicable, a copy of the Drug Identification Number assigned
to the product by Health Canada's Health Protection Branch.
A panel will then evaluate your product and determine if it qualifies
for exemption. If it qualifies, but must be monitored, the branch will send one sample bottle for laboratory analysis
to confirm that the alcohol content and/or salt content is the same as that stated on the sample labels. If the lab
confirms the content, we will then advise you of the product's exempt status and any terms and conditions we impose
on the making, importing or sale of the product. If it is not confirmed by the lab, we will ask you to re-apply,
possibly under another exemption category.
For more information
Information on exemption policies and application procedures
for each category of non-beverage alcohol are available on-line. Go to:

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