37 replies to this topic

[Curtis McMillan]

New make spirit. Moonshine has an illegal overtone that's great for sales. If we are truthful with our customers its just new make spirits.

[Spirits Review]

As a reviewer of such things I've been struggling with that one myself - trying to classify all those different products - by different names into a coherent category where my readers can find them.
I've been kind of old school and originally lumped them under "American Whiskey" meaning not Bourbon or Rye - (which have their own categories with admittedly a few spirit in those categories that might be a stretch )
American Whiskey being a geographic catchall for all whiskey that did not qualify for inclusion in Bourbon or Rye because of aging, blending or ingredient ( at least in my opinion).
Of course I could have been a smart ass and put it under "Vodka" but thought that wasn't very useful.
I'm thinking of starting a new category "White Whiskey (Unaged)" as a new category in my reviews, and if a spirit has a little age it will still go there with an explanation/description/modifier that states the aging.
I think an analogy is the whole Silver/White/Plata problem with Mexican spirits such as Sotol,Tequila, and Mezcal , some are not aged (and make a big thing about never touching wood), some are and people use different names . Although I admit it seems the public can usually figure them out because they have been around much longer and old was the exception no the rule - which is the opposite of whiskey ( in the last 100 years or so anyway).
Short form: I'm going with White Whiskey because it's reasonably comprehensive and easier to understand. The other terms have a little too much connotation or expectation about proof, quality, possibly too technical .

[JohninWV]

We call our product white whiskey and have a bold statement on the front left side that says "Aged zero months". It's becoming a big seller for us.
It's just white dog diluted to 100 proof. There are some folks out there calling product between 160 proof and 190 proof white whiskey. I think High West does this and maybe Death's Door (I'm not sure about those guys). I think the distillation proof makes these much different. It's more like a blend of our vodka and our white whiskey. They are both interesting products.

[porter]

JohninWV, on 06 April 2011 - 09:37 AM, said:

We call our product white whiskey and have a bold statement on the front left side that says "Aged zero months". It's becoming a big seller for us.

Under the regs doesn't it have to have 'some' amount of aging to hold the whiskey classification? I think there's one on the market who ages "...72 hours or less..." on the label. So how are you getting the COLA to pass with 0-aging?

[Paul Tomaszewski]

§ 5.22   The standards of identity.

Class 2; whisky. “Whisky” is an alcoholic distillate from a fermented mash of grain produced at less than 190° proof in such manner that the distillate possesses the taste, aroma, and characteristics generally attributed to whisky, stored in oak containers (except that corn whisky need not be so stored), and bottled at not less than 80° proof, and also includes mixtures of such distillates for which no specific standards of identity are prescribed.

Bottom line, if it's white and you want to call it "whisk(e)y," it's either "aged for a period of time in oak containers," no minimum req. there, or it's at least 80% corn mash...  or at least that's how it's SUPPOSED to be.

[JohninWV]

Our whiskey is classified as "other whiskey" similar to Buffalo Trace.
Here's their label approval:
https://www.ttbonlin...=08261001000250

The standards of identity and the BAM don't exactly say the same thing.


I would like to add a few things:
1. My white dog/white whiskey has "the taste, aroma, and characteristics of whiskey generally attributed to whiskey" as mentioned in the BAM, section 4-2. I also don't think there's anyone that's being fooled that it's an aged product. After all, I make it very clear that its not. I understand section 5.22 says differently.
2. Most importantly, if you are gonna argue that our product doesn't fit the definition of whiskey with a TTB agent (for your own label approval) please don't use me as an example.

[absaroka]

TTB picks the type/class designation for COLA when submitted.  If it meets what the label says, then they will classify it as such.  If not, you may have to clarify or re-submit.

[coop]

Bonanza, on 06 April 2011 - 11:49 AM, said:

I’m in discussion since 6 month with the local INH (Ecuador), something like the TTB in the States.

They don’t want me to call my spirit “Corn Whisky” (Whisky de Maiz), neither they allow me to call it “Corn Liquor”  (Licor de Maiz).

Last news is that they accept “Grain Spirit” (aguardiente de cereals).

I will accept that for now but want to rectify it with some political power to Corn Whisky.

I would be very thankful if someone can email me a label approval as “Corn whisky” like John posted.

If I have some US or other countries approvals in my hand I could force the INH to add the category.

Thanks for any help.

Joe

You can go to our site www.coloradogolddistillers.com and take a  look at our "Corn Whiskey" label which has been approved by the TTB for the last 3 years. Coop TTB ID 09322001000145

[cowdery]

The traditional term in the United States for unaged whiskey was 'common whiskey,' but that was long before the Standards of Identity.

Of all the terms mentioned in the original post, 'whiskey' is the only one that is regulated. It's probably the most desirable word to use, with or without a modifier, for any flavorful grain spirit. Since whiskey must have contact with oak by law, we have to teach people that wood-aged whiskey can be clear. That doesn't seem like a huge obstacle. So 'white whiskey' is a good term. The average person's intuitive sense of what it means is largely correct, which is a great recommendation for it, and rare.

'Moonshine' is tough to resist because it resonates with the consumer, but using it on a legal product corrupts the true meaning of the word, leading to confusion. Many people mistakenly believe that moonshine is a type of distilled spirit when, in fact, it is any distilled spirit produced illegally. Using the term 'moonshine' on an unaged whiskey product is doubly wrong since virtually all true moonshine is sugarjack.

I don't like 'American whiskey' as a catch-all category, although 'other American whiskey' is fine. The natural meaning of 'American whiskey' is a whiskey made in America, an umbrella term that includes bourbon, rye, corn, blended, Tennessee, i.e., everything not everything except the major categories. It has never been all about bourbon and even Tennessee whiskey has to be respected as a de facto type even if it's not de jure.

'White Dog' is nice because it is colloquial and sounds vaguely 'bad' (like 'moonshine') but it's also traditional and authentic. I've been hanging around American distilleries for the past 30 years and folks in the industry probably use the term 'white dog' the most. It seems to roll off the tongues of distillers in Kentucky and Tennessee most naturally, that's for sure. 'New make' is similar but doesn't have any tang. It's bloodless, but equally authentic. 'New make' is for use in company that might not get 'white dog,' especially non-native English speakers. Both terms also get around the need to have oak involved.

You can't realistically make any of them proprietary so there's some value in trying to think of a term that communicates what it is as effectively as 'white whiskey' but that you can own.

Back at the beginning of my career I used to hear 'high wines' a lot but almost never now.

[nick jones]

This is an interesting question, since it always seemed to me that it would have been a huge omission for the writers of the standards of identity not to include a "catch all" category for those beverages that were so outrageous and odd that the writers of the standards of identity would never have thought of them when writing the standards.

I'm no English major, and I apparently misspell whiskey often, but the way I read § 5.22 CFR, whiskey might have a touch of catch-all to it.  Wouldn't the following be a perfectly complete general description of whiskey?

"‘Whisky’ is an alcoholic
distillate from a fermented
mash of grain produced at less than
190° proof in such manner that the distillate
possesses the taste, aroma, and
characteristics generally attributed to
whisky, stored in oak containers (except
that corn whisky need not be so
stored), and bottled at not less than 80°
proof..."

I see no need to further expand upon this "general" definition of whiskey, especially since the Standards go on to define the various different types of that class (or classes of that type... I'm still new to this...) yet the Standards do add something to this general definition of whiskey:

"and also includes mixtures of
such distillates for which no specific
standards of identity are prescribed."

I find this very interesting.  If "such manner that..." refers to the following manner, wouldn't "such distillates..." refer to the following distillates?  If "such distillates" is meant to refer to the previous clause, then why is it plural?  The previous clause has only one subject: "whisky".  

The way that I read it, all mixtures of distillates which have no specific standard of identity would fall into the category of whiskey.  Is whiskey (or whisky) intended to be the catch-all category?

I'm not saying that I agree with it, but I find it difficult to read the law any other way, though I'm sure that one could read it any way that one wants, as is the fashion these days.

Nick

P.S. I think that this really highlights the need for the Standards to be seriously revisited.  In my opinion, they've been left alone for so long that they're beginning to verge on nonsense.

[delaware_phoenix]

Whiskey is a distilled spirit made from grain. Now perhaps there should be a distinction as between eau-de-vie (clear) and brandy (brown, aged in wood). Time between distillation and bottling should have no import with respect to class, only the means of maturation, since it's only in that way that the spirit is transformed.

There may well have been valid reasons in 1938 for declaring something labeled as whiskey must have been stored in oak. Historically, if the distillate came from grain is was whiskey, if from fruit it was brandy.

TTB is approving COLAs and formulas for products labeled as whiskey that have never been stored in oak. Perhaps Chuck can confirm with his industry sources whether BT and HH are transferring their white dog/new make whiskey from the usual stainless steel tanks into some kind of oak container before bottling. But my guess is they're not doing that.

[JohninWV]

Cheryl,
Like you, I'm fairly certain that BT isn't aging in oak. I could be wrong.

I think the catch all as nick referred to is a good point. It's also clear that the BAM just says the "taste, aroma, and characteristics of whiskey generally attributed to whiskey" with no mention of oak until it gets down to the type.

[Denver Distiller]

You'll notice that Maker's Mark soon to be released White Dog was approved as a Distilled Spirits Specialty, a term us Absinthe distillers are far too familiar with.....

So they obviously thought that Formula approval was the way to go, and either they or the TTB think it isn't whiskey.

BT submitted a formula, too, but the TTB or BT called it an "other whiskey".  As per usual, the waters are very muddied.

[coop]

[quote name='Denver Distiller' date='07 April 2011 - 08:41 AM' timestamp='1302187317' post='9968']
You'll notice that Maker's Mark soon to be released White Dog was approved as a Distilled Spirits Specialty, a term us Absinthe distillers are far too familiar with.....

So they obviously thought that Formula approval was the way to go, and either they or the TTB think it isn't whiskey.

BT submitted a formula, too, but the TTB or BT called it an "other whiskey".  As per usual, the waters are very muddied.
[/quote
When I read requirements I called mine Colorado's Own Corn Whiskey. I put mine on oak but for a short period of time only. I will try to attach a photo of mine. Coop

Attached Files

•  Corn Whiskey - White Background.jpg   52.16K   30 downloads

[JohninWV]

Todd,
In the link I posted from BT's COLA, there isn't a formula number, right? If so, wouldn't it be filled out in box 10?

[Denver Distiller]

Sorry for the confusion, John, I was referring to this COLA:

www.ttbonline.gov/colasonline/viewColaDetails.do?action=publicFormDisplay&ttbid=10264001000042