Section 31.33 - Retail dealer in beer(a)General. Except as otherwise provided in paragraph (b) of this section, every person who sells or offers for sale beer, but not distilled spirits or wines, to any person other than a dealer is a retail dealer in beer for purposes of this part. Every retail dealer in beer 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 beer. The following persons are not retail dealers in beer within the meaning of this part:(1) A limited retail dealer as described in §31.35, or(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).