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DEFINING "CRAFT" DISTILLERY


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Good points. How difficult would it be to define "agricultural raw materials"? Is a flavoring considered, in this case, to be a "raw material"? This list of qualifiers could be a mile long. May I suggest we take heed of the earlier advice to let the market sort out quality. The simple criteria are the easiest to manage at this point. I'm thinking that a producer adding artificial flavorings is not using an agricultural raw material in that case; but a producer using actual herbs and other natural ingredients is excercising a "craft" approach. The question is where do you draw the line? Is a producer who uses a concentrate of a natural ingredient (perhaps a distilled essence of some herb or fruit), using a raw ingredient or a derivative and does it matter? I'm inclined to favor any naturally developed derative like tinctures or reductions, if they are concentrates of agricultural raw materials, not synthesized compounds made in a lab. In the end the honest craftsmen will police the dishonest craftsmen and the marketplace will be the judge.

And by the way, the policing and judging can be passed to the Fed at such time as we all agree on the standards and our own organizational structure and present ourselves an our position on such things to the general public through the proposed lobbying efforts. If we expect the Fed to allow a producer to enjoy reduced taxes and other considerations, we should be the community that defines the scope of our own influence. Do we go forward on parallel paths, tax reduction and defining the term "craft producer"? I think it is important. Then the Fed can decide about those who might take improper advantage of the definition to claim reduced tax obligations. An accepted term and a defined group of constituents will go a long way toward tax relief. The cheaters will be found out by either the Fed or by the community eventually. And frankly it is our feeling (as it relates to our own products) we are not in the same class or have anywhere near the same product that a blender who pours a dose of chemical flavorings into GNS. And I would not want some unfounded fear that someone will cheat to stand in the way of moving forward on a program that benefits the real craft producers.

Can we try to hone down this proposal and comment on its merits or lack thereof? Any suggested clarifications or additions to bat about? The discourse is good. Now let's aim at an acceptable declaration.

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Think we might just need to separate this definition:

- One for our lobbying efforts, which will need to be simple and easy to implement (continue on lobbying thread)

- Another for marketing and self-identification, which can touch on all the issues of quality, place and craft that matter to us on multiple levels

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Throughout all of this, I would suggest that North American distillers need to be cognizant of North American distilling traditions. Many people have purchased stills made in Europe and received instruction from the makers of those products. Many people who want to make whiskey, especially those who want to make malt whiskey, have studied Scottish practices. I'm not saying there is anything wrong with that or that you have to be bound by North American practices and traditions. It's not an end-all-and-be-all, I'm just suggesting that a craft producer in North America should be as well informed as possible about North American practices and traditions, and it just might be to your advantage to acknowledge and adhere to at least a few of those traditions. This is why I keep fighting the prejudice against continuous distillation. I'm also confident that the people who are participating in this discussion are among the best informed and most conscientious individuals in this young industry, but you need to be cognizant of what else is out there.

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Cheryl- Exactly in which sense do you mean " I also think craft producers don't add GNS to dilute their products"?? What if you distill a gin and it is the correct flavor balance, but too much of it, too big a flavor? So you add GNS and water until it is the correct strength and abv.?

Or are you talking specifically about gns/whiskey blending?

No, I wasn't specifically referring to the latter. I think the example you gave is an excellent example of where craft comes into play, where craft = skill and knowledge. In the example you cite, I'd put the first batch in a barrel(s), and make a second batch, in just the same way, but with the botanicals toned down a notch from where I'd want them. Then I'd mingle the two when bottling to get things just the way I wanted it. I'd probably save some of that "too strong" gin for the time when I misjudge the botanicals and it comes out too weak.

Perhaps there are standards of identify that preclude folks from doing that.

And I know many of us are quite new to professional distilling and we're bound to make mistakes along the way. And the (unfortunate) nature of the business is that we often start in the hole, and we're pressed to be successful. So shortcuts and quick fixes become a tantalizing way to keep doing what we love. Craft distilling is a bit of a mindset, like that commercial the where the they made money the old fashioned way.

I'm sure if someone came along with a restored/replica of an early 19th century Tennessee whiskey still (continuous) there'd be agreement they were practicing a craft. :lol:

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The differences between equipment and craft, as Melkon put it, are critical. Chuck's observation that there should be no difference in our definitions between a "craft producer" using a pot still, a column still (though some may dispute if a column contributes to the "craft" nature of the undertaking) or a teakettle still on a stovetop is well made. As Melkon and others continue to hold, it's about skill and care, ongoing education and improvement of the product, and putting some soul into your work.

Though I do not personally agree with using a column to produce "craft spirits", I do agree to disagree and move forward. If we are all agreed that it's about "craft" and not about hardware, we should leave the discussion of column vs pot behind and move on.

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I think this should all be viewed like what happened in the record industry. Major labels vs. Independent labels. Indie labels are smaller and more maneuverable in a business sense, and were more sensitive to what the market wanted. They play in between the cracks of the large pigeon holes the Major labels used. They are sometimes owned partially or wholly by a larger label but are given autonomy to continue doing what they did to become successful. Is the term independent or indie or boutique distiller something we should consider using?

On the flip side I've tried many NGS based products slapped into a fancy bottle that tastes like @#$* from "micro-distillers". Someone like that calling them selves a "craft" or "artisan" distiller is like a man who doesn't know poop goes down hill calling himself a master/journeyman plumber.

For this reason I come to Mr. Coals defense for if we aren't careful we will destroy these terms in the public eye. Chuck Chowdery expressed this in another post too in different words.

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While I agree it is a worthwhile pursuit to protect to the extent possible the terms "artisan" and "craft" as they relate to distillers, they are not terms of art and therefore subjective. We would be wasting our time trying to police the use of the terms outside any legal use, for instance if a State defines the term relative to distilling ("craft distillery"). Let the marketplace decide if a maker's product is shit or not. Worry about your own product and be true to the terms as you understand them and as we all eventually accept them. But as I've said before this, there will always be those who will choose to work at the fringe of the definition, which is okay.

I'd like to ask if we can begin to get some concensus on the proposed definition. It is not perfect, but all the specific qualifiers can be added down the road to sort out the types of "craft producers". Reread the latest proposed definition, of "craft producer" leaving aside the question of "distiller" vs "infuser".

R

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Here's a conundrum.

For lobbying purposes, such as persuading governments to give you a tax break relative to the large producers, you want to emphasize things like small volume, local company using local suppliers, potential for growth, new industry, good for tourism, that sort of thing. That's what legislators and regulators care about. They won't be too moved by "craft."

But for marketing purposes, craft and quality are everything.

So, why have a trade group? I think it's much more for lobbying collectively than it is for marketing collectively. The lesson, then, is pitch a big tent.

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I agree with "micro" instead of "craft." Micro seem to better imply smaller, lower volumes. "Micro," as a term, seems to have worked for the craft beer industry.

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I agree about Micro. Artsianal and Craft talk about how, Micro focuses on size, plus has the cachet built up by micro-breweries the last two decades. It's a term folks understand, or at least think they do.

I agree with "micro" instead of "craft." Micro seem to better imply smaller, lower volumes. "Micro," as a term, seems to have worked for the craft beer industry.
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As a member of the Board of the BA (Brewers Association) when they defined craft, I learned

1. Any organization must have a definition for membership. ie. Am. Distillers

2. Festivals ie. GADF (Great American Distillers Festival) can and maybe should have standards for entry. 3. Competitions should have category standards.

4. The consuming public and retailers

a. May not care. It's only taste.

b. May care – misled

5. The grey will never go away.

Do you need Dirt, a still, or can you rent on for a day – share one.

6. To get to issue have to name names. Who are we excluding – ie What Bill calls merchant bottlers, Sub Rosa,

Hood River Distilling

7. Good to face early on – type BA definition excluded many we loved: Widmer, Red Hook, Kona, Goose, Lennies

The following is meant as a jumping off point, though it does seem to cover the meat of the subject. Time to define the terms: "craft" and "artisan" distillers. Here's my first attempt. Comments welcome.

****

PROPOSED DEFINITION OF "CRAFT" OR "ARTISAN" DISTILLER

"Craft distillers produce alcoholic beverage spirits by distillation, or by infusion through distillation or redistillation. Maximum production for a "craft" or "artisan" distiller should not exceed 50,000 proof gallons per year. The "craft" or "artisan" distiller utilizes a pot still, with or without rectifcation columns, for distillation of beverage spirits. A distiller starting with neutral spirits produced by others, who redistills without substantially altering the neutral character of the spirit may not be said to be a "craft" or "artisan" distiller.

***

This definition deliberately excludes producers of infused products making use of alcohol which the producer has not made from the fermentation and/or distillation process. It is inclusive of the distiller who starts with grain neutral spirits and then redistills as a function of infusion or some other process which substantially alters the neutral character of the original spirit. It excludes the distiller who starts with gns and merely runs it through a still again to create another neutral spirit; or starting with grain neutral spirits only adds flavoring and/or color unless those changes are introduced as the result of distillation, not merely as additives. It excludes blenders or bottlers who buy spirits from another distiller to blend and bottle it under another brand. The "distiller" must distill.

Ralph Erenzo

Tuthilltown Spirits

Gardiner, NY

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Okay, taking some more of this into consideration, let's try this wording:

Micro-Spirit makers produce beverage spirits primarily from agricultural raw materials, including but not limited to grains or fruit. A Micro Producer utilizes a variety of techniques in the preparation which substantially change the character of the original material, including but not limited to: infusion, batch distillation and/or redistillation. Micro Spirit Producers prepare and bottle up to 65,000 proof gallons of product per year in a single licensed premises.

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Micro-Spirit makers produce beverage spirits primarily from agricultural raw materials...

I read "primarily" to imply that there are alternate raw materials to agricultural. Are there any beverage spirits made from raw materials other than of agricultural origin?

In the spirit (no pun intended) of "less is more," how about:

Micro Spirit makers produce beverage spirits utilizing a variety of techniques which substantially change the character of their raw materials, up to 65,000 proof gallons of product per year in a single licensed premises. These techniques include, but are not limited to: infusion, distillation, and/or rectification. [1]

The gist of the statement (as I see it) is:

1) that we're not trying to exclude any of the methods of spiritous beverage production. [2]

2) that we're establishing a volume criterium to define "micro"

3) that we don't want it any more complicated than that.

Cheers,

Paul

[1] I'm using "rectification" in place of re-distillation

[2] While on the surface, continuous distillation may not seem to apply, it's not inconceivable [3] that it could be utilized within our scale.

[3] I keep using this word, but I really do know what it means ;)

Edited for clarity and I can't type for diddly today

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Princess Bride. Oop, wrong forum.

Totally agreed. I think the proposed definition as it has evolved is generic enough, and casts a broad enough net to be fully inclusive and focused on the point. Perhaps the defined term should not be "craft", but "micro". Any comments anyone?
Absolutely. The whole point of the matter is one of scale. "Craft" or otherwise is a separate issue.
I read "primarily" to imply that there are alternate raw materials to agricultural. Are there any beverage spirits made from raw materials other than of agricultural origin?
Not that many of us would be interested in using them, but artificial flavors and colors would fit in there as would many so-called "natural" flavors and colors.
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Not that many of us would be interested in using them, but artificial flavors and colors would fit in there as would many so-called "natural" flavors and colors.

Indeed, but I think that's why any mention of raw materials (primary, secondary, etc.) isn't necessary in what we propose as the definition of what we're about.

In my humblest of opinions, of course,

Paul

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I think it is important to stress the "agricultural" nature of the raw materials. And the inclusion of "primarily" leaves room for addition of non-ag materials such as natural flavorings and such. I do agree that it may be unnecessary to mention fruit and grain, however the idea is to make clear the traditional basic ingredients. Perhaps this revision to the revision proposed above:

Micro Spirit Producers make alcoholic beverage spirits utilizing a variety of techniques and agricultural raw materials including but not limited to grains and fruit, which substantially change the character of the raw materials; up to 65,000 proof gallons of product per year in a single licensed premises. These techniques include, but are not limited to: infusion, distillation, blending, and/or rectification.

I have added "blending" to the techniques. And reversed "Micro Spirit makers produce" to be "Micro Spirit Producers make" to maintain a "title" to the defined class of producers. Also I added "alcoholic beverage" to the first sentence for clarity and to be closer to the Fed and States' wording.

Perhaps Chuck you can comment on the above from an attorney's point of view.

R

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James Wagner, ESQ, an attorney with alcohol experience in the DC area took a look at the proposed definition and comments:

I believe that it is wise to err on the side of broadness in definition...to factor in changing goals and desires of producers. Much of the discussion shows a subtantial range of subjectivity on the "craft" or "artisan" nature of the production. I'm assuming that the prime goal of defining "Micro Spirit Producers" in the first place is to gain a statutory benefit, including tax treatment and reporting requirements. If that is the case, the focus should be on reaching consensus on the volume limitations.

As far as proposed edits, I would suggest minor edits as follows:

Micro Spirit Producers make alcoholic beverage spirits utilizing a variety of techniques and agricultural raw materials including but not limited to grains and/or fruit, which substantially change the character of the raw materials. The techniques used include, but are not limited to: infusion, distillation, blending, and/or rectification. A Micro Spirits Producer may make no more than 65,000 proof gallons of product per year in a single licensed premises.

Let's please begin to get participants and distillers on board so we can begin to get this to Legislators as a concensus definition accepted by most of the legitimate small producers.

R

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The following suggestion does not change the meaning of the paragraph, just its structure:

Micro Spirit Producers may make no more than 65,000 proof gallons of product per year in a single licensed premises. Micro Spirit Producers use a variety of techniques which substantially change the character of the raw materials. Those techniques include but are not limited to: infusion, distillation, blending, and/or rectification. Micro Spirit Producers use agricultural raw materials including but not limited to grains and/or fruit.

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I'm not clear whether a neutral party would interpret "65,000 proof gallons of product per year in a single licensed premises" as allowing:

a] only one licensed premise, capped at 65,000 gallons

b] a cap of 65,000 gallons per each licensed premise, multiple sites being ok

IANAL, so I'm not sure whether this is unclear language or simply my own fogginess.

-Andrew

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I agree with Chuck on this. The Fed licenses single Premises as a distillery, each as a single licensed facility with specified components and infrastructure. And in principle I also agree with this>

Read your piece today Chuck. I think the equipment people use does not distinguish them as craftsmen. If a distiller is using a column or a pot or a teakettle on the stove, none of that hardware speaks to the care and concept behind what he produces or the process he uses along the way. I'm thinking you agree; however I got the impression from the piece you feel that a real American whiskey maker has a particular form to follow to be considered such or an American craft distiller. I hope I'm wrong in this interpretation. The "traditions" I see are perhaps four or five generations old and the nearly total absence of the scale of the new American distiller has not existed for that time in the US. If we go back past Prohibition there are uncounted examples of "traditional" distilling that include makeshift, bootstrapped, scavanged, bought and moved, innovation in the creation of small distillery spirits. So the return of this kind of experimentation and innovation speaks to a return of real traditional whiskey making, I think, not a deviation from it.

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