Jump to content

distilled versus produced and bottled


captnKB

Recommended Posts

Everyone should of course follow their own path and dreams, while staying within the TTB regs. The issue is, what's most important to your particular business, and how that fits into the industry at large. Of course part of this is the very term "Craft", and if that carries a premium, and if so, to what degree.

It's easy to see the success and failure of Craft, by looking at the brewery industry. In that product group there is no "brewed in Iowa" shipped to CA, put in a barrel, and then magically labeled "produced in CA". It just doesn't happen. In that industry, consumers know with relative certainty that the Craft Company they are purchasing from, brought the product from grain to glass.

To offset the devastating losses actual Craft brewers have created for big brewers, Big-Beer has been on a buying rampage of small brewers, and continuing on with their small production models. It's worth the expense, as the Craft beer carries a price premium. Even that however is now experiencing a backlash from millennial consumers, who are pushing back against brands that are mega-corporate owned.

With that in mind, in the distilled spirits industry Big-Alcohol is pushing for a "non-issue" of craft vs. mass production, by making it appear that they are in fact one in same, regardless of size or origin. This would have never happened (i.e. the consumer would have seen the difference) if not for actual start-up Craft distillers who are riding the Potemkin-Craft train, while they are waiting for their own spirits to mature. Of course there are also those who have no intent of ever actually producing anything, but that's a different story.

The New Craft Distillers are essentially driving the resurgence of the whiskey industry, and with it, carrying along Potemkin-distillers (both mega and new bottler/bubblers). But to what eventual end? Will the consumer see it for what it is ? Is the entire industry, both mega and small at risk, if there is no discernible difference between the two?

At the rate it's currently going, Big-Alcohol would probably be best advised to literally give away 10,000 PG to each of 500 Craft Distillers in the country, so those little "distilleries" would have a decent, aged product to sell under their own little brands. This would keep the Craft Spirits Distillery industry perceptually viable in the eyes of the consumer. That would allow Big-Alcohol to continue to flood the market with their own "Potemkin-Craft Labeled, same old products" at price points above and beyond what they have historically charged under their old brands.

As for aspirations of "running a nationally distributed product"? I don't even know what that means. I'm a distiller :)

  • Thumbs up 1
Link to comment
Share on other sites

And the 1897 act of Bottled in Bond?

Bottled-in-Bond or Bonded. This means the whiskey was made at a single distillery, by one distiller in one distillation season, aged for at least four years in a federally bonded and supervised warehouse, and bottled at 100 proof.

I like this other than the four year requirement. But some such term could easily work for the craft distiller. There could be BONDED SPIRITS...produced aged and bottled on site...call it "ANYTHING WE DECIDE" and push forward the definition of fermented, distilled, aged (if required), bottled in one distillery.

The fact that some of the Big Boys have begun branding BONDED (JD BONDED) cracks me up. It signifies to me that their other products have outsourced components.

Link to comment
Share on other sites

The fact that some of the Big Boys have begun branding BONDED (JD BONDED) cracks me up. It signifies to me that their other products have outsourced components.

The big guys have been doing BIB for quite a while. Just no one cared about it and not using it gave them the flexibility to blend older product with younger to get consistent flavor and color profiles. Yes they could also blend product from one of their other (or someone else's) distillery, but for brands with only one plant in the US this would just be a secondary benefit. They have transitioned to more BIB because whiskey enthusiasts know BIB is a good value, Heaven Hill's BIB products are all extremely affordable and quite tasty

Do you guys really think consumers are reading and discerning the fine print?

Some people might be, but most not. I think ultimately distillers should worry about how it tastes, as that is the one thing we can control. That has been our focus here, and I believe it will make a bigger difference than who makes it when it comes buying a second bottle.

.

Link to comment
Share on other sites

This topic hits hard. Its very frustrating having so many people committed to being a Distillery, and producing their own product. And at the same time, so many money driven corporations and said "craft distilleries" buying bulk whiskeys, and hiding the facts.

They make every attempt to hide the truth, and put the bare minimum on the product.

I would say from my experience being a millennial, is that even most millennials have no idea this "smoke and mirrors" is happening. Even if they read the label, they don't truly understand the difference.

My $0.02

Cheers

Josh

Link to comment
Share on other sites

I don't necessarily want to say that I am not money driven. I do want to make a living!

I also see the Craft Label as "THE" big deal! It is one of the few things a "craft distillery" (fermented, distilled, aged as nec and bottled) has to sell itself. Call it "chain of manufacture." We should know every drop of product we bottle intimately.

Anyone here bought a barrel of GNS and it wasn't right? Had to send it back?

Link to comment
Share on other sites

The big guys have been doing BIB for quite a while. Just no one cared about it and not using it gave them the flexibility to blend older product with younger to get consistent flavor and color profiles. Yes they could also blend product from one of their other (or someone else's) distillery, but for brands with only one plant in the US this would just be a secondary benefit. They have transitioned to more BIB because whiskey enthusiasts know BIB is a good value, Heaven Hill's BIB products are all extremely affordable and quite tasty

Some people might be, but most not. I think ultimately distillers should worry about how it tastes, as that is the one thing we can control. That has been our focus here, and I believe it will make a bigger difference than who makes it when it comes buying a second bottle.

.

The original law (pushed by E.H. Taylor) was for the big Kentucky distillers, since it allowed them to avoid paying tax when the whiskey was older than 3 years old. At that time, you paid tax OR you could BIB. And the requirement in terms of distillery origin, etc., was to distinguish the product from Kentucky from whiskey being produced elsewhere of lesser quality. So, ironically, everything was reversed from what it is now: the Kentucky bourbon was the product trying to protect itself from other cheaper products produced elsewhere. In fact, the FDA of 1906 did the same thing. Kentucky distiller Taylor tried to get all whiskies produced differently than Kentucky bourbon to be declared as imitation whiskies, but was unsuccessful. Instead, the category "straight" was created, and the rules that it must be produced in only one state and blended only with straight whiskies from the same state. That was so you could NOT label a whiskey as Colorado straight bourbon if it was actually made in Kentucky. Those rules apply today, but only to a "straight".

Link to comment
Share on other sites

I'm pretty sure Tennessee and Kentucky are the only 2 states with an appellation - which comes with regulation of state name in the labeling of a product. The TTB's permissibility of state name usage on a whiskey label without the spirit being distilled in-state is complete bunk, and it's certainly opens the door for "misleading statements". I get why many NDP's opt to put their home state on the label of out-of-state sourced juice and reap the sales benefits of a consumers belief they are buying a home-town whiskey. Super disingenuous but a smart business move since our government currently chooses not to regulate that aspect of labeling.

Lenny, there is a Tennessee whiskey, but there is no Kentucky whiskey. Kentucky straight bourbon refers to the use of a state name for a straight whiskey, which must be made in one state and if blended only with straights from the same state. Hence, you can make Colorado straight bourbon whiskey or Illinois straight rye whiskey. Any state can have its state's "appellation" for a straight whiskey.

Link to comment
Share on other sites

Lenny, there is a Tennessee whiskey, but there is no Kentucky whiskey. Kentucky straight bourbon refers to the use of a state name for a straight whiskey, which must be made in one state and if blended only with straights from the same state. Hence, you can make Colorado straight bourbon whiskey or Illinois straight rye whiskey. Any state can have its state's "appellation" for a straight whiskey.

I'm pretty sure follow you — There can be a "Colorado Straight Bourbon" (ex. peach street distillers) that is held by regulation to having to produce every drop of that bourbon in the state it claims and be at 2yrs matured at minimum. Or... there can be a "Colorado Bourbon" which is either legitimacy distilled in colorado but matured less than 2 years -or- it can be juice from anywhere else in the country so long as it conforms to the standards of identity for a bourbon.

In my estimation, a huge issue with this aspect of spirit regulation by the TTB is that the onus falls on the consumer to understand either what "straight" means (my guess: 95% of buyers do not know what straight means), or to flip a bottle around and read the small print. Meanwhile, producers—who's product seems to account for the majority of "craft" spirit sales on the shelves—can delight in the intentional deception of customers by using their home state as a descriptor to position the product as locally produced ...and the TTB doesn't mind that in the slightest. That's fucked up.

Link to comment
Share on other sites

So what is the definition of "straight"?

I thought it was at least 2 years in new wood.

Reading the above posts I think there might be more to it than that.

(I am an Aussie distiller, we have very few regulations, but to counter that we pay huge excise tax)

Link to comment
Share on other sites

From my good friend, Chapter 4:

Whiskey:

  • Spirits distilled from a fermented mash of grain at less than 95% alcohol by volume (190 proof) having the taste, aroma and characteristics generally attributed to whisky and bottled at not less than 40% alcohol by volume (80 proof)

Bourbon:

  • Whisky produced in the U.S. at not exceeding 80% alcohol by volume (160 proof) from a fermented mash of not less than 51 percent corn and stored at not more than 62.5% alcohol by volume (125 proof) in charred new oak containers.

Straight Bourbon:

  • Bourbon whisky stored in charred new oak containers for 2 years or more.
  • “Straight Bourbon Whisky” may include mixtures of two or more straight bourbon whiskies provided all of the whiskies are produced in the same state.

Straight is defined for all the styles in the same way. Except corn, which is used or uncharred.

Link to comment
Share on other sites

Thanks for the Chapter 4 link Robert

I am intrigued by the following from chapter 4

STRAIGHT WHISKY³ · Whisky produced from a fermented mash of less than

51 percent of any one type of grain and stored in charred

new oak containers for 2 years or more.

So if you use 100% rye it cannot be called "straight" after 2 years

It must be a typo.

And if it is a typo and it meant "not less than" then you are not allowed to make a strait whisky with 4 grains at 25% each.

I am glad I don't have to follow TTB rules

Link to comment
Share on other sites

no - what it is saying is that if you have less that 50% of any particular grain, it is not designated by "a grain" . i.e 45% Rye, and you can't call it rye whiskey. You just call it whiskey. 51% rye, and you can call it Rye. As for the age, it's saying that any whiskey stored in New Charred Oak, 2 years or longer, can be described as Straight. Of course you don't have to, but it is allowed. Further if it is less than 4 years old, you must have the age on the label. The only exception is that after 4 years in New Oak, you can drop the age statement if you so choose.

Link to comment
Share on other sites

This topic hits hard. Its very frustrating having so many people committed to being a Distillery, and producing their own product. And at the same time, so many money driven corporations and said "craft distilleries" buying bulk whiskeys, and hiding the facts.

They make every attempt to hide the truth, and put the bare minimum on the product.

I would say from my experience being a millennial, is that even most millennials have no idea this "smoke and mirrors" is happening. Even if they read the label, they don't truly understand the difference.

My $0.02

Cheers

Josh

I agree with this very much.

Unless you are in the know, then you don't know. I don't have billions to educate the public. Just look how many billions of gallons are sold. Do you think anyone buying UV or Smirnoff really come from.

put what you want on there. who cares? i don't give a crap what put on your bottle, Just mine.

Take care

Link to comment
Share on other sites

It seems to me that to simply require every bottle of spirits regardless of type of spirits to state

Distilled by [Distillery], in [City], [state]. Redistilled and/or Bottled by [Company], in [City], [state].

is a simple straightforward solution to create complete transparency in all spirits

I'm no expert at TTB rules and regs, but doesn't TTB Rule 5.36(d) already cover this for most whiskies (with a a few exceptions)? Chuck Cowdery was making a lot of noise about this a few years back. I think a couple of MGP/LDI customers ran afoul of it and made some news.

...

§ 5.36 Name and address.

...

(d) State of distillation. Except in the case of “light whisky”, “blended light whisky”, “blended whisky”, “a blend of straight whiskies”, or “spirit whisky”, the State of distillation shall be shown on the label of any whisky produced in the United States if the whisky is not distilled in the State given in the address on the brand label. The appropriate TTB officer may, however, require the State of distillation to be shown on the label or he may permit such other labeling as may be necessary to negate any misleading or deceptive impression which might be created as to the actual State of distillation. In the case of “light whisky”, as defined in § 5.22(B)(3), the State of distillation shall not appear in any manner on any label, when the appropriate TTB officer finds such State is associated by consumers with an American type whisky, except as a part of a name and address as set forth in paragraph (a) of this section.

Link to comment
Share on other sites

Create an account or sign in to comment

You need to be a member in order to leave a comment

Create an account

Sign up for a new account in our community. It's easy!

Register a new account

Sign in

Already have an account? Sign in here.

Sign In Now
×
×
  • Create New...