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Everything posted by bluestar

  1. Federal Excise Tax and my thoughts

    I can see an advantage to lowering prices for product at the lower end, that is otherwise competing with bigger brands, like vodka, and where you can easily ramp up production to meet the growth in demand. For limited production high end product, it probably doesn't make sense, unless you are competing head-to-head with another local producer.
  2. Federal Excise Tax and my thoughts

    Not only that, but the TTB always has the option of not granting the DSP's request under such ownership and physical plant structures.
  3. Topping off barrels

    Actually, now that I read the response carefully, I see it does not really answer the question. It tells you that you don't need a formula. It does not answer what age you have to put on the bottle. Why? Because even if you do what you propose, the resulting product is still whiskey, and so your COLA can be submitted without formula. But it does not tell you if your COLA can have an age statement that includes time beyond when the water is introduced, the specific question you were asking. I think you need to query the COLA folks on this, not the formula folks.
  4. Topping off barrels

    If you are saying that any addition of water will not stop the aging clock, as I mentioned before, that can not be right in ALL cases. If sufficient water is added so the gauged product no longer meets the requirement of a whiskey (below 80 proof) say, then the category/type has changed. So it must now become about how much water is added. Never mind the difficulty of trying to gauge in a barrel (get accurate proof and volume or weight) without removing it (which would stop the clock).
  5. Topping off barrels

    Like I said, add enough water, and maybe it ain't the same spirit. Okay, another thought experiment: if I add spirit to partially fill, and then add more later to complete the fill, usually the way we treat that is that the START of the aging clock would be when the final addition is made to the barrel. So, another effect of adding water could be that it means you START the clock, although I doubt the expectation would be to do that after a significant time in the barrel in that scenario. As for the "rolling barrel" stuff, that's just nonsense. What happens in the barrel stays in the barrel, so to speak. Why we are having this discussion is because something is from outside the barrel is being added to it. By the way, there is a corollary question: If I remove spirit from the barrel, does it stop the clock? Obviously, the answer is no for sampling, for example. But since there is no de minimis, you could in principle remove half the contents of the barrel at one age, let the rest of it continue to age, and then later bottle that as older whiskey? Hmmm. And if that were so, and you could add water, you could refill the barrel with water after removing spirit, and continue to age it. Thus, the barrel could produce more than its filled volume in final product aged in new cooperage. Hmmm. Sounds like we are going down a rabbit hole.
  6. Topping off barrels

    Unfortunately, that is something of a non-answer. Specifically, you don't indicate the maximum amount of water you may add. The cited TTB ruling is specifically calling out the ability to add harmless materials (water in this case), that would typically be added in production or processing (not storage) for the type. But for that ruling to apply, the amount added must be less than 2.5% volume. So maybe they are trying to say you can add 2.5% water and not require a formula, because it will still be whiskey. Which begs the question, what if we add MORE than 2.5%, since then the TTB ruling would not apply?
  7. Blending Our Vodka and NGS Labeling

    Hmmm. There might be a reading of this that is in between. Dhdunbar is correct, you will need to submit a formula if you buy or make NGS that is not designated as vodka at the time of production, and you want to change it to vodka. And two ways to do that is to redistill it or filter it as explained in 5.27 (and you will need a formula approval for the TTB to determine the final product is vodka). Interestingly, item no. 3 in section 5.27 (l) suggests a third alternative: mixing with anything other than water (which won't change classification and type). That could be mixing NGS from one source with another, or maybe with a mouth-feel additive like sugar or glycerin. Then you will have to submit a formula to prove to the TTB the resulting spirit meets the requirements for vodka. That might require you to provide specifics on how the NGS was made, to essentially show that its method of manufacture assures a product that could have been classified as vodka, but wasn't at the time. But for you to say you produced, you have to do something to it beyond just repackaging it, which would be bottled by. But this does suggest, that contrary to dhdunbar, maybe you could mix your distilled vodka with purchased NGS and call it vodka, if you submit a formula for approval that describes the NGS and possibly how it was made by its source, so that the TTB decides the resulting product is vodka. It might be they won't approve. But perhaps this route is suggested by the CFR?
  8. private labeling, contract bottling

    Just rereading the CFR: actually, I think you don't have to indicate where it was bottled so long as the contents were otherwise produced and processed at the cited distillery. See section 5.36 (a) 2: where instead of saying who it was bottled by when bottled for a distillery, you need only say who it is distilled by, unless it was a Bottled in Bond whiskey. From my reading of that, you might not be able to do any rectification, meaning you might have to bottle it as received from the distillery?
  9. private labeling, contract bottling

    So it would say distilled by me, IL, and bottled XYZ, IA?
  10. Regional Differences for Aquavit?

    Swedes traditionally use a rye spirit base, and often include dill with the caraway (in fact, dill can be the dominant flavor in some styles), and usually don't barrel age. Danes may include some cumin with the caraway, Aaborg is known for including amber in one version, and can be barrel aged. The Norwegians specifically use oak for aging, often used sherry barrels, and age for longer periods than other countries. Other spices and citrus can be used as well, and varies by producer. Some add caramel coloring. We have done a Swedish style (rye based, with significant amounts of dill with the caraway, other brown spices), but long aged in used bourbon barrels.
  11. winery in distillery

    I know that setups were approved in years past that the TTB is more stringent about now. In particular, things like separations between brewery and distillery, or winery and distillery, or bonded versus general premises.
  12. winery in distillery

    We want to add a small winery to the distillery. We know that the bonded winery has to show a separation from the bonded distillery, although we know of places where that has been as little as a low fence or even tape on the floor. Anyone with recent experience along these lines? Does the winery have to have access to non-bonded space directly, or can it be through the bonded distillery?
  13. Basic Amaro recipes

    Most are liqueurs, so they are not redistilled, they are extracts in spirit with sugar and other flavor and coloring added.
  14. How to keep cooling water from going bad

    FYI, Acid #5 is a mixture of nitric and phosphoric acids, with some detergent. It is rated for food processing use. It will passivate stainless. Must avoid contact with chlorine containing materials. Especially useful where regular detergent cleaning does not do a good enough job of removing organics, it will neutralize the akaline detergent like citric, but will also further work on any residual organics. While it should passivate stainless, it will continually etch copper or other etchable metals, so I am not so sure it is the best choice for adjusting pH for recirculation systems, unless they are all stainless.
  15. private labeling, contract bottling

    Joe, curious, if we send you our juice to bottle, and you send it back in bond, how do we have to label it? Clearly, I can say distilled by me. Do I have to say bottled by you? Can I simply say produced by me? Etc.
  16. Bourbon and rye for sale, 53g barrels

    Those seem like reasonable prices. Are they pot distilled whiskey done at your distillery? What char are the barrels?
  17. Topping off barrels

    Simple thought experiment: assume you are in storage, don't worry about it being in barrel. You have spirit in a tank at a given proof. You add water. You are required to gauge when you do this. In principle, there is no de minimis, so in the thought experiment you could assume something like adding 20 gallons of water to 1 proof gallon of spirit. A barrel, in addition to being the required vessel for aging, is also a storage vessel. So again, you would be required to gauge when you do this. You don't have to gauge when some "accident", such as leak, evaporative loss, angels share, devils cut, etc., changes things, until you remove the spirit from the vessel. Small amounts of sampling are also treated in this way, as an "accidental" loss, but larger draws would have to be at least recorded. So, at a minimum, you are likely to have to gauge if you were to add water to the barrel, recording the change in volume and proof. Unless there is something in the CFR that says you don't, which I can't find, at least not for whiskey. I do agree, you could read 19.326 to suggest you might not have to do this for brandy or rum, but of course, you would gauge if there were any transfer of spirits, at least to record what what was moved from where and to where. This concept that there is no de minimis shows another problem with addition of water: obviously, there must be a limit, since you could have 50%+ loss in angels share after long aging, decide to add water to refill the barrel (which is not whiskey going into the barrel), and the resulting proof will be so low in the barrel, the product would no longer qualify as whiskey. This is not spoken to anywhere in the CFR, and I assume that is in part because the CFR simply presumes this will not happen: you can not blend in something that is not whiskey with whiskey and expect the category and type to be the same. Even 19.326 probably assumes you won't do that, but rather will top off or blend like spirits (rum with rum, brandy with brandy), unless you are proofing down and gauging. This analysis also suggests that adding water, by virtue of the possibility of changing the category or type of spirit, would require a formula approval.
  18. Topping off barrels

    The definition of age is the period of time the product spends in barrel (section 5.11, "Age"). If you add water to the distillate in barrel, one or both of two things must be true: the product is now the old distillate with the water added, which is a new product, and the clock starts for that product to age in what is now a used barrel; or you have "rectified" the product by adding water, and the clock stops in that barrel. The point being, the product before and after water is added is now no longer the same product, it would need to be gauged and reentered in the records, as would any distillate anyway along the way of production or processing. When in storage, the product can not be altered, at least not intentionally. Another way to think about it is that the water added, or anything added, has not spent the time up until that point in the barrel, and has not aged to that point. Hence, the contents of the barrel are now a blend of aged and unaged product.
  19. Distillery in Malt Plant

    Of course, each TTB reviewer will give their own opinion, but we had extensive discussions about using the distillery for non-distilling activities, and in the end, they convinced us that we had to not only separate bonded premise from general premise, but that there needed to be a separation between general premise and non-distillery space, although it did not require the same level of security as the bonded premise. In the end, this makes sense, since you are required to report the acceptance of the malt into the distillery for production as a separate activity from malt being sold outside or used for another purpose. Similarly, any grains brought into the distillery would have to be reported on your production report, and that becomes ambiguous if the grain might not be used for distillation. The reporting and tracking of raw materials brought onto distillery premises and its security is part of how the TTB assures you are not "cheating". Now, I would presume you could sell malt from the distillery, but to do so, you would have to report all the grain coming in and all the malt going out somewhere in your monthly reports. Otherwise, you would have to show a way that you physically separate the malt and grain accepted for production, so that only malt used for production goes into the monthly report.
  20. Distillery in Malt Plant

    And you are selling malt to others?
  21. Topping off barrels

    For US, clock stops with any addition to the barrel.
  22. Distilling Cider With High acidity

    Supposedly, you can't get significant copper in the vapor path, since most salts thermodynamically prefer to be in solution than in the vapor phase, unless at very high concentrations. So it is the copper on the condensing surfaces that exit the still that are a concern (condenser, and lyne arm if it slopes into the condenser).
  23. Distilling Cider With High acidity

    You can't "salt out" the acetic acid. You will form the acetate salt, but that is still volatile, so you still end up with the acetic acid in the vapor. What happens in the first distillation doesn't matter so much as the second distillation, since you can get rid of the copper acetate by a clean distillation (with no copper condenser). But so long as you have acetate or acetic acid in any quantity in the charge, and you have copper in the condenser, you are in danger of generating copper acetate. Supposedly, you can try to passivate the copper condenser so that it won't be attacked by the acetic acid, but if anything removes or undermines the passivation, you can generate the copper acetate. So, while the acidic charge is indication of acetate in the pot as acetic acid that will form copper acetate, neutralizing the acid might not get rid of the problem. You have to tie up the acetate. Or get rid of the copper.
  24. "Would you like fries with that?" Moments

    Probably good idea, but you do have to use caution if done in the context of a room that sells cocktails, depending on state laws. In our state, laws prohibit doing things that encourage increase of consumption of drinks by economic incentives. For years, we didn't have Happy Hours for that reason. But specifically, if you did something like say offer: "order 3 cocktails, and you get a $5 discount on a purchased bottle", that might be prohibited, because it encourages increased consumption in a sitting at the bar.
  25. Hopped Whiskey(?)

    Okay, now you muddied the waters. You can use various chemical, non-flavor, additives as part of production if they are recognized as being standard or typical, like adding certain yeast nutrients or maybe anti-microbials. If you want to be sure, you submit a formula for approval. You are supposed to put all of those in your formulas now (used to be you did not have to mention yeast or nutrients, but now they do require it, even water added). In that context, that might get approved for use, even in whiskey. But that the chemical is derived from hops is incidental, it is not hops. It is left to the TTB to make these judgement calls. What you can not do is assume: TTB should allow use of hops as a botanical in making whiskey because TTB allows a hop-derived, flavor-free chemical to be used in small quantities for an anti-microbial. Nice try, but no dice.