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Barrel Aged Gin formulation/cola


rtshfd

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How are people handling barrel aged gins nowadays?  We are producing a gin from original distillation.  It's a distilled gin by class.  By barrel aging this and stating "barrel aged gin" are we changing that class?  Would we be able to put an age statement on it?  "aged for 3 months in whiskey barrels?" 

By simply barrel aging this gin does that now make it a distilled spirit specialty?

Thanks in advance!

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We are working on a barrel rested Gin, with the formula approved and now the label is almost done. 

The TTB is becoming more of a pain in the butt when it comes to barrel aging spirits. You can't use the words "Barrel Aged" it has to be "Barrel Rested". No age statements are allowed, you can't even put "Barrel Rested" on the same line as Gin. You have to put it above or below. 

I wasn't even allowed to say "Rested in once used Whiskey Barrels". I couldn't make any reference to what was in the barrel previously. I know that others have gotten labels approved in the past, but they are much more stringent now.

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Ask the TTB. But if you want to put barrel rested on the label, you need to have an approved Gin formula. That formula is going to have the barrel as a flavor, and then have it in the Method of Manufacture that the gin was rested in the barrel.

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I just got off the phone with formulation at the TTB and they basically said "barrel rested" is a compromise but since gin as a class isn't aged (as of now) no age statements or references to "aging" are allowed.  

The big surprise was that if we have an existing approved gin product that is going into barrels, as long as I adhere to the above, it doesn't need further formulation.  The agent said that "it wouldn't be a productive use of yours or ours time" to get a second formula approval.  Basically it's still a gin that just so happened to be stored in a barrel for a period of time.  

The main takaways from my convo:

* no age statements, "barrel aged" or references to other spirit classes (rested in whiskey barrels). 

* no formula needed if the gin itself is already approved.  

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1 hour ago, rtshfd said:

The main takaways from my convo:

* no age statements, "barrel aged" or references to other spirit classes (rested in whiskey barrels). 

* no formula needed if the gin itself is already approved.  

Confirms what others and I have said.

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23 hours ago, bdsammy94 said:

Ask the TTB. But if you want to put barrel rested on the label, you need to have an approved Gin formula. That formula is going to have the barrel as a flavor, and then have it in the Method of Manufacture that the gin was rested in the barrel.

No, it does not. So long as the gin that is not barrel stored does not need a formula, neither does the barrel stored. You stored it. In a barrel. Aging is not recognized. You don't need to say what you stored it in.

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Well, don't know what to tell you but when I submitted my Barrel Rested Gin label they kicked it back for a formula with the barrel resting in it. My label finally got approved this week.

You might have gotten luckier with whomever at the TTB that was working on your label. 

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if you make gin without using other finished spirits such as GNS, (aka - original distillation), you do not even need a formula... here is my 'Oak Barrel Gin', distilled from malted malted barley I have 'Barrel Rested Gin' in for approval, but expect kickback since they seem to have become more finicky in the past few months.

https://www.ttbonline.gov/colasonline/viewColaDetails.do?action=publicDisplaySearchBasic&ttbid=15299001000367

https://www.ttbonline.gov/colasonline/publicViewAttachment.do?filename=Half Mine - Oak Barrel v2.jpg&filetype=l

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On July 21, 2016 at 3:27 PM, bdsammy94 said:

Well, don't know what to tell you but when I submitted my Barrel Rested Gin label they kicked it back for a formula with the barrel resting in it. My label finally got approved this week.

You might have gotten luckier with whomever at the TTB that was working on your label. 

Not luck, neither of my barrel stored gins needed a formula. But neither is a redistilled gin (which needs a formula). Are you saying that your barrel stored gin is a distilled, not a redistilled gin? Or are you saying that you had a redistilled gin, that had a formula, that did not include barrel storage? If the latter, yes, IF you have a formula, and you are going to barrel store the gin, then you have to put that in the formula. And, some of the less experienced TTB COLA reviewers simply get it wrong. I have had about 50% of my COLAs that were kicked back, later approved after pointing out the error to a supervisor.

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Could you send me the contact info of the supervisor?

The gin is a distilled gin so no formula needed for the regular label. When I wanted to change to a "Barrel Rested" Gin they kicked the COLA back for a formula approval.

I asked the TTB Agent in the Formula division why I need a formula, and I was told that any color added to the gin must be approved because color is not a part of the gin category. Fine. (I believe aged gin is getting a new sub-category here soon)

I submitted a formula for the distilled gin, rested in a barrel, got the approval and then they approved the COLA. 

True story.

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16 hours ago, bdsammy94 said:

Could you send me the contact info of the supervisor?

The gin is a distilled gin so no formula needed for the regular label. When I wanted to change to a "Barrel Rested" Gin they kicked the COLA back for a formula approval.

I asked the TTB Agent in the Formula division why I need a formula, and I was told that any color added to the gin must be approved because color is not a part of the gin category. Fine. (I believe aged gin is getting a new sub-category here soon)

I submitted a formula for the distilled gin, rested in a barrel, got the approval and then they approved the COLA. 

True story.

That smacks of my experience with absinthe.  I'm currently trying to muscle through an absinthe label approval and the agents are forcing me to say artificially colored because spirits are colorless so anything is artificial (even natural herbs). That, obviously, is a negative marketing angle especially because it's a DSS and has the SOC right in the middle of the front label.  

An aged gin category seems imminent...it can't be here fast enough.  

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On July 31, 2016 at 3:51 PM, bdsammy94 said:

Could you send me the contact info of the supervisor?

 

Contact the TTB COLA ask for a supervisor. The person you are talking to is incorrect. There is nothing in gin that discusses what color it is. And you did not say anything about color in your COLA, did you?

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  • 2 weeks later...
5 hours ago, RCHagemann said:

How detailed does the formula have to be for barrel aged gins?  Does anyone have an approved formula example that they'd be willing to share?

If you followed the thread, the gist should have been there is no difference in the formula for a gin that is barrel aged or not, except that if you need a formula, and you plan to barrel age the gin, you have to say that in the formula.

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This whole color things is a fiasco.  

Bourbon, for example, is brown, but it comes off the still clear.  Just because a material or process adds color, it does not become a coloring agent.  TTB's beverage manual, which I do not like to quote, since I prefer regulations, says:

  • The use or addition of coloring/ flavoring/blending materials will not cause a change in the class and/or type if the materials used or added can be considered “harmless.” (See “HARMLESS COLORING/FLAVORING/BLENDING MATERIALS” section of this chapter)
  • COLORING MATERIALS · STATUS nColoring materials must be approved by the U.S. Food and Drug Administration (FDA)
  • Approved coloring materials are categorized as “certified” or “non-certified” ·
  • APPROVED COLORING MATERIALS All coloring materials approved for use in distilled spirits are listed below:
  • Certified Colors FD&C Blue #1 FD&C Blue #2 FD&C Green #3 FD&C Red #3 FD&C Red #40 FD&C Yellow #5 FD&C Yellow #6
  • NOTE: The lake of each certified color, except for FD&C Red #3, listed above is an approved coloring materia.
  • Non-certified Colors Annatto Extract Beet Extract Beta Carotene Caramel Carmine (Cochineal Extract) Elderberry Extract Grapeskin Extract (Enocianina) Paprika Saffron Titanium Dioxide Turmeric

The point is that flavoring materials which add color are not coloring materials, since the above list includes all of the approved coloring materials.  Therefore, if you are not required to list the flavoring material (in most cases you are), you are not required to have a formula.  Gin is a good example of an exception to the formula requirement when it is produced by original distillation.  Formulas for gin are required only when they are produced by redistillation of neutral spirits or by compounding.  They are not otherwise required by regulation or TTB's pre-COLA evaluation procedures.  

I'd say resting the gin in a barrel is the equivalent of aging the bourbon in a barrel.  It does not require a formula.  Of course, you can't claim age on gin, but that is another argument. And the whiskey argument has a flip side.  TTB is pretty damned free to adopt any policy it wants.  For example, it does require a formula when you label a product "whiskey" without further designation as a type of that class.  It does that under the pre-COLA evaluation guidelines.  It apparently made the requirement as an internal control to combat the erroneous approvals of l"white whiskey" and "unaged whiskey" designations that became a problem a few years ago..  

But certainly do not surrender to the claim that you have to state that the gin is artificially colored if it picks up color from the barrel or from the botanicals used to make it.  That is pure nonsense.  

 

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dhdunbar, just to be clear about what I was contributing, I only pointed out that IF you need a formula otherwise, you need to include the aging (barrel storage) information in the formula. but agreed, a formula is NOT require for a gin just because it is stored in oak barrels and takes on color or flavor as a result.

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Yea, that was clear.  Cotherman said that too and I was just being complete.  I understood.

It is only the color thing that brothers me.  The claim that a change in color = a requirement for a formula comes from a misunderstanding of the standards of identity, regulation and past policy as expressed in things like the beverage alcohol manual.  Statements like that are undisciplined imagination that have no footing on which to stand.  TTB has to implement the law through regulation and regulations are issued only after notice and opportunity for hearing.  TTB then has considerable latitude to clarify and amplify the regulation by rulings.  The courts give great deference to regulatory agencies in that regard.  But that does not sanction individual employees fabricating from whole cloth requirements that do not exist.  Rules apply to TTB as well as industry.

It is the sort of thing that makes dealing with TTB frustrating at times. It's employees are too free to invent their own rules and concoct silly rationales to support them.  Occasionally nonsense like the neutral spirit classification for Jack Daniels unaged rye product, which was distilled at around 140 proof, but which TTB insisted, over Daniels's objection, was a neutral spirit.  It was an awkward moment.   The color issue has the same roots - TTB employee's misunderstanding of TTB's own requirements - it just doesn't have the sex appeal of the Jack Daniels blunder.

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On 8/17/2016 at 11:23 AM, dhdunbar said:

Yea, that was clear.  Cotherman said that too and I was just being complete.  I understood.

It is only the color thing that brothers me.  The claim that a change in color = a requirement for a formula comes from a misunderstanding of the standards of identity, regulation and past policy as expressed in things like the beverage alcohol manual.  Statements like that are undisciplined imagination that have no footing on which to stand.  TTB has to implement the law through regulation and regulations are issued only after notice and opportunity for hearing.  TTB then has considerable latitude to clarify and amplify the regulation by rulings.  The courts give great deference to regulatory agencies in that regard.  But that does not sanction individual employees fabricating from whole cloth requirements that do not exist.  Rules apply to TTB as well as industry.

It is the sort of thing that makes dealing with TTB frustrating at times. It's employees are too free to invent their own rules and concoct silly rationales to support them.  Occasionally nonsense like the neutral spirit classification for Jack Daniels unaged rye product, which was distilled at around 140 proof, but which TTB insisted, over Daniels's objection, was a neutral spirit.  It was an awkward moment.   The color issue has the same roots - TTB employee's misunderstanding of TTB's own requirements - it just doesn't have the sex appeal of the Jack Daniels blunder.

I've found that escalating within the COLA team and going through the formulation team sometimes helps. The formulation agents seem to have a better idea on what is required for each spirit type and what the TTBs stance is on certain nuances, "barreled" gin being one of them. If you get a formulation agent's stamp of approval put in the "notes to agent" section of you cola app to contact the formulation department to clarify. 

I have an absinthe that is flavored with herbs after the distillation and they're trying to make me say artificially colored. We can all imagine what that will do to our marketing/brand perception. 

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Just to give everybody an idea about how sensitive the ttb is with regards to the word "aged" with regards to gin, we recently redesigned our labels and the application was rejected solely because the filename contained the phrase "barrel aged."  The actual label contained no age statement.  

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