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rtshfd

Barrel Aged Gin

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rtshfd    8

We are currently aging some gin.  I've seen through many topics here that the TTB is not allowing "Barrel Aged" on a gin bottle.  Is that still the case?  Are there any recent experiences that I can use to guide our choices for what to label it?  Must this be formulated as a Distilled Spirit Specialty?

I'm seeing many barrel aged and age stated gins on the shelves...

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bluestar    41

What the CFR actually says is that no statement of age can be made for a gin. So generally, the wording "Barrel Aged" is rejected, since one could construe that as a statement of age (although I personally disagree, since no period is listed). The ambiguity here may be why some have rarely gotten a label approved with that phrase. For sure you can not state an age, like "aged six months", even on rear, like "we aged our gin for a year in used barrels". But you can say other things, again at the discretion of the TTB reviewer, like "Barrel Reserve", or "Barreled". But sometimes they can be fickle. We had them approve for one gin the phrase on the rear in body copy "this barrel reserve is set aside in used bourbon barrels before bottling" but not allow that phrase on a similar product. Go figure. Roll the dice. I think this is one of those areas where the industry should consider lobbying to modify the law, and allow age statements similar to rum.

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rtshfd    8

I've seen many bottles that explicitly say "barrel aged" and an age statement of "aged for x months."  The inconsistency of the review process is maddening.  Admittedly all of us new producers are putting quite a strain on the agents doing the reviews, but in a case like this we are being genuine.  The gin is literally barrel aged for x months.  How is that trying to be misleading?

grrrr

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sonnyk    0

For the specific reasons noted by others about COLA rejections for using any terminology with "aged" for Gin we went with "Barrel Finished" right on the front label and it was approved in a three week period.

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bluestar    41
On June 28, 2016 at 11:13 AM, rtshfd said:

I've seen many bottles that explicitly say "barrel aged" and an age statement of "aged for x months."  The inconsistency of the review process is maddening.  Admittedly all of us new producers are putting quite a strain on the agents doing the reviews, but in a case like this we are being genuine.  The gin is literally barrel aged for x months.  How is that trying to be misleading?

grrrr

By the way, when you say you have "seen many bottles" do you mean you saw the approved COLA from the TTB? I have "seen many bottles" that are modifications of pre-existing approved labels, but have not actually been approved with new COLA.

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jb789    0
On ‎6‎/‎28‎/‎2016 at 3:31 PM, sonnyk said:

For the specific reasons noted by others about COLA rejections for using any terminology with "aged" for Gin we went with "Barrel Finished" right on the front label and it was approved in a three week period.

Did you have to submit a formula for this?  I'm trying to find this out for our barrel-aged gin.  Luckily, the turnaround time for Formula approvals right now is 1 day, so even if I do have to submit a formula, it won't slow me down much.  BUT, I'm worried that if I submit a formula, it will become a Distilled Spirits Specialty, and they won't even let me call it a gin at all... Is anyone else submitting formulas for their barreled gins?

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After four years of selling a gin finished in a variety of different barrel types, all of which received COLA approval as gin, we decided to change our label. This new label (but the same gin) failed. The formula reviewer decided it MUST be classified as "Distilled Spirits Specialty". So the COLA could no longer be passed as GIN. I'm calling them now, and will report back here what I learn.

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bluestar    41

Nothing in the gin regulations prohibits aging in barrel, nowhere nohow, so it should never have to be specialty. But if something in your label suggested to them that juniper is no longer the dominant flavor, for example, that would cause it to be a specialty. I have had gins that I would claim don't have sufficient juniper in them to really be called gins.

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jb789    0
On 8/12/2017 at 7:46 AM, bluestar said:

Nothing in the gin regulations prohibits aging in barrel, nowhere nohow, so it should never have to be specialty. But if something in your label suggested to them that juniper is no longer the dominant flavor, for example, that would cause it to be a specialty. I have had gins that I would claim don't have sufficient juniper in them to really be called gins.

Update: Although the regulations don't say anything about aging/not aging gin in barrel, the COLA officials have told me multiple times that if a gin is aged in barrel, it's no longer a gin, it's a distilled spirits specialty.  We tried to get our label passed with a formula attached, calling it Barrel Gin and including a statement of composition as Gin Finished in American Oak Barrels, but they said that "Gin" can't be in the fanciful name because it's not really a Gin, it's a DSS... So we're still working on the label.  The thing I hate about some of these regulations is that they're trying to make it so the consumer isn't misled, but sometimes by doing that, the label ends up being more misleading (or at least confusing) than it was before!  

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bluestar    41
1 hour ago, jb789 said:

Update: Although the regulations don't say anything about aging/not aging gin in barrel, the COLA officials have told me multiple times that if a gin is aged in barrel, it's no longer a gin, it's a distilled spirits specialty.  We tried to get our label passed with a formula attached, calling it Barrel Gin and including a statement of composition as Gin Finished in American Oak Barrels, but they said that "Gin" can't be in the fanciful name because it's not really a Gin, it's a DSS... So we're still working on the label.  The thing I hate about some of these regulations is that they're trying to make it so the consumer isn't misled, but sometimes by doing that, the label ends up being more misleading (or at least confusing) than it was before!  

Simply wrong, at least for the past few years. Also, the regulations say something SPECIFICALLY about aging gin in a barrel:  

(d) Other distilled spirits. Age, maturity, or similar statements or representations as to neutral spirits (except for grain spirits as stated in paragraph (c) of this section), gin, liqueurs, cordials, cocktails, highballs, bitters, flavored brandy, flavored gin, flavored rum, flavored vodka, flavored whisky, and specialties are misleading and are prohibited from being stated on any label.

So, it doesn't say you can't age or store it, just that you can't make a statement or representation as to age or maturity. There are dozens of counter examples out there of gins that have been stored in barrels and allude to it in other ways, including 3 of our products. This would be tantamount to saying that you can't store it in a specific container, which is nonsense. What you can't do is say that the product is aged. Talk to a TTB manager. I suspect either you have a novice officer giving you bad feedback, or that there is something else in your formula or label that is tripping the requirement for distilled spirits specialty: for example, if you say your are flavoring or aging the product with oak after production, that becomes a flavored gin or a distilled spirits specialty. Don't say that.  I am not surprised the phrases you suggested would not be allowed. Composition can say nothing about barrels (suggests aging), you can not use a fanciful name with it either. But you can add a general label text that can allude to it. We have been able to use "Barrel Reserve" on a few of our labels, including gin, where an aging statement can otherwise not be made.

By the way, specialties can't be represented as "aged" either, per the reference above. So, storing the product in barrel can not be the discerning point for separating a gin from a distilled spirit specialty.

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PeteB    44

Every time I see you US distillers trying to satisfy your label requirements I am glad I am an Aussie.

I have a desktop printer and rolls of my generic labels. Whenever I make a new product I run off a few labels with the name of the product and a description.

As long as the information on the label is truthful, has bottle size, ABV and number of "standard drinks" then all is good.

(The main down-side to being an Aussie distiller is the rip-off excise tax we pay.)

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