(a) General. Except as otherwise provided in paragraph (b) of this section, every person who sells or offers for sale distilled spirits, wines, or beer to any person other than a dealer is a retail dealer in liquors for purposes of this part. Every retail dealer in liquors must comply with the registration and other requirements of this part, unless the dealer is covered by an applicable exemption under subpart D of this part.

(b) Persons not deemed to be retail dealers in liquors. The following persons are not retail dealers in liquors within the meaning of this part:

(1) A retail dealer in beer as described in §31.33(a),

(2) A limited retail dealer as described in §31.35, or

(3) A person who sells or offers for sale distilled spirits, wines, or beer only as provided in §31.61 through §31.64 or §31.65(a).

(26 U.S.C. 5122)