27 C.F.R. § 31.33
(b) Persons not deemed to be retail dealers in beer. The following persons are not retail dealers in beer within the meaning of this part:
(2) A person who does not sell or offer for sale distilled spirits or wines and sells beer or offers beer for sale only as provided in § 31.61 through § 31.63 or § 31.65(a).
(26 U.S.C. 5122)