Rev. Rul. 54-388

Advice is requested whether grain neutral spirits may be labeled as grain alcohol.

Under the internal revenue laws relating to liquors, and regulations issued pursuant thereto, two types of plants are authorized, i.e., industrial alcohol plants and distilleries. Both may produce spirits of high proof. However, in order to determine the origin of such spirits and to avoid confusion between the products of the two types of plants, the product of an industrial alcohol plant (used primarily for industrial purposes) is designated as `Alcohol.' However, spirits of 190 degrees or more of proof produced at a distillery (used primarily for beverage purposes) are required, under section 183.531 of Regulations 4, to be labeled as `Neutral Spirits.' Therefore, although there is no chemical difference between `Neutral Spirits' and `Alcohol,' the difference being merely one of origin, neutral spirits may not be labeled as `Alcohol.' However, there is no objection to the inclusion on the labels of neutral spirits of a statement such as `Grain Neutral Spirits is the same as Grain Alcohol.'