18 replies to this topic

[Scott @ Twenty2Vodka]

Had an elaborate post prepared, but rereading it was boring, so lets keep it simple, cause this is a simple topic.

According to the TTB's Standard's of Identity; 27 CFR, Part 5, Section 22  (google 27 CFR 5.22), the definition of vodka is provided as part of "Class 1: Neutral Spirits or Alcohol", and comprises the following:

Quote

Quote:
"(a) Class 1; neutral spirits or alcohol. “Neutral spirits” or “alcohol” are distilled spirits produced from any material at or above 190° proof, and, if bottled, bottled at not less than 80° proof.

(1) “Vodka” is neutral spirits so distilled, or so treated after distillation with charcoal or other materials, as to be without distinctive character, aroma, taste, or color."
End Quote.

Therefore, to the artisans out there who make vodka too.  What do you call vodka?  Is some character permissible, or "no way Jose"?

Personally, I'm in the "no way, Jose" camp.  Any distillate with noticeable odor and/or flavor should not be permitted (by the TTB) to put "vodka" on their label.

Q: What's noticeable?
A: If you make a martini with it, and before it's to your mouth you are thinking "What in the hell is that odor?", that would be noticeable to me, and I can name 5 brands quickly that fit into that category...

Q: What would it be called then?
A:  I dunno, brandy? Schnapps? Anything but vodka...

Q: How does one enforce such a rule?
A: Don't know either...I guess with their (the consumer's) wallets.... ?

Anyway, what do you think?

[Chris Martin]

I'm not yet an artisan making vodka, but will be!  Can I chime in as a consumer?  

IMHO, I think it's time to update the rules.

By default, vodka should be eminently mixable with minimal influence over the mixer.  But something like Hanger One is a pretty good example of a vodka with very subtle qualities that don't conflict with a mixer.  Tito's has a hint of character too.  Farther out on the spectrum is something like Napa Vodka (which I think is amazing) with a very distinct and powerful nose... it makes a very unique and delicious vodka martini, but it wouldn't be my first choice for some mixed drinks.  Or take Dry Fly, which to me has a very distinct "wheaty" quality.

I think the general trend is towards "more" (in pretty much all spirit categories) rather than "more refined"... we went through that already.  The field is so crowded, it only seems logical that distinction is the name of the game.  Of course, a "distinction niche" can still be found in refinement as well.  I just think the rules are outdated in today's marketplace.

My 2 cents...  

[Gwydion Stone]

My 2¢:

I agree with Chris, it's time to update the rules, but that just not going to happen.  Instead the TTB has thankfully chosen not to enforce the vodka standards of identity very strictly.

The CFR-prescribed identity for vodka is notably within the class of neutral spirits, as Scott shows, but I've never tasted a micro-distilled vodka (as opposed to re-bottled GNS) that qualifies for the legal description.  Some are very nice, many are downright funky, and some are just un-aged whisky (on the other hand, I recently had a "whisky" that was just a barrel-aged vodka).

I mean no disrespect to those who choose the neutral vodka route, goodness knows there's a market for it, but for me it's a very large "why bother?"  Neutral spirits can be had very cheaply.  They're the starting base of many fine drinks, but a drink on their own?

On the other hand, vodka in all its early origins was a handcrafted and not neutral spirit.  It was made—hold on to your hats—by actually distilling multiple times in a real pot still instead of by trying to calculate how many plates equals "distilled a bajillion times."

[Jonathan Forester]

I'm with Chris and Gwydion. I think that if it is distilled by the legal definitions, and has flavor, that is ok.

We are just putting on the market this month a spirit that is technically/legally a neutral spirit, distilled up to 95+%, but it still has a hint of flavor and character, with a subtle sweetness. We're not calling it vodka, but a neutral spirit.

If I ever decide to make vodka, maybe next year once our main facility is completed, I will most definitely want the character to come through.

[Napa Vodka]

Chris Martin, on 03 October 2011 - 09:37 PM, said:

I'm not yet an artisan making vodka, but will be!  Can I chime in as a consumer?  

IMHO, I think it's time to update the rules.

By default, vodka should be eminently mixable with minimal influence over the mixer.  But something like Hanger One is a pretty good example of a vodka with very subtle qualities that don't conflict with a mixer.  Tito's has a hint of character too.  Farther out on the spectrum is something like Napa Vodka (which I think is amazing) with a very distinct and powerful nose... it makes a very unique and delicious vodka martini, but it wouldn't be my first choice for some mixed drinks.

Thank you Chris, Im glad you enjoyed it! We recently launched our Napa Vodka, Distiller's Blend - which is made from a blend of American Winter Wheat and the same Single Vintage Sauvignon Blanc that goes into our Vintage Reserve. The Distiller's Blend still has unique character, but makes a much better mixer than our Reserve. BTW... I agree with you about Hangar One. Its a fantastic spirit and has perhaps paved the way for other American Craft Vodkas made with character to be launched. If a consumer wants neutral vodka, they're out there - especially from foreign brands - but I think part of what makes American Craft Vodka so interesting and unique is the distillers own unique personality. They're part craftsman and part renegade who choose to go against the grain, which I respect. I guess its part of our American Heritage. Regardless of ingredient (and there are many different ones now), if Vodka can be made with desirable character that highlights the main ingredient used to make it, then it should -  otherwise Vodka would all taste the same and really rather pointless.

If you find yourself in Napa, please let me know. I'd like to welcome you in for a complimentary tasting.

Cheers!

[cowdery]

I just laugh whenever someone here posts that TTB should 'change the rules.' The rules can be changed and sometimes are, but the way it usually is stated here is in a vague, petulant, tea party, 'government out of my distillery' way.

Writing rules and, therefore, changing them, requires careful analysis of potential interpretations and results, especially unanticipated results. I very rarely see a poster offer a cogent and compelling argument for a specific change. It's more a self-centered, "I want the rules to allow me to do whatever I want," which is more like no rules rather than new ones.

Presumably, all vodkas sold in the United States satisfy the rules, yet they don't all taste the same, and therefore they do have distinctive character, so whose ox is getting gored so badly that we really need a rule change?

[PeteB]

TTB ---"as to be without distinctive character, aroma, taste, or color."

I am sure there are a lot of artisan vodkas out there that have slight "character, aroma or taste" but they are all different.

I am certainly not a lawyer, but could you look at it this way--

The word to focus on is "distinctive". What "note" is distinctive or unique about ALL these products that you can say that "note" belongs to vodka?

The only distinctive thing is that there is very little of anything axcept alcohol.

I think the main rule to follow is  TTB-- "distilled spirits produced from any material at or above 190° proof"

[nick jones]

cowdery, on 20 October 2011 - 03:09 PM, said:

Presumably, all vodkas sold in the United States satisfy the rules

You presume too much, dear Cowdery.

I laugh pretty much every time you ever post anything on this forum, and especially when go on your vague and petulant tirades about how sensible 27 CFR is and how reasonable the TTB are.

While I wholeheartedly agree with you that some posts on this forum tend to focus on problems with the law rather than solutions to its flaws, I hardly think that chastising people for their honest attempts to address the law's shortcomings gets us anywhere worthwhile.  And I think that this topic brings up a very good point, and I believe that all of the views expressed above are worthy of serious consideration.

Perhaps before you next chastise someone for their seemingly futile attempts to change the law, you should read over a letter that Thomas Jefferson wrote to James Madison back in 1789.  Jefferson raised the interesting point that laws are so difficult to change, that it would be better if they simply expired after a certain time period.  In his words:

...the power of repeal [of laws] is not an equivalent [to their expiration]. It might be indeed if every form of government were so perfectly contrived that the will of the majority could always be obtained fairly and without impediment. But this is true of no form. The people cannot assemble themselves. Their representation is unequal and vicious. Various checks are opposed to every legislative proposition. Factions get possession of the public councils. Bribery corrupts them. Personal interests lead them astray from the general interests of their constituents: and other impediments arise so as to prove to every practical man that a law of limited duration is much more manageable than one which needs a repeal...

As true back then as it is today, no?  Alas, Jefferson's ideas never ended up making their way into our legislative system, much to your delight, I'm sure, Those rapscallions and their tea parties... so uncivilized...

So here we are, burdened with antiquated laws that we can only hope to someday repeal and, as you say, replace with our own best efforts at legislation (which, as Jefferson so aptly points out, are themselves doomed to become obsolete as well).

So unless you have a cogent and compelling reason why we on this forum shouldn't openly discuss the strengths and weaknesses of federal law with the chance of someday managing (against the will of people like you) to repeal an antiquated law and replace it with a new and reasonable one, you just might want to keep your chortling to yourself.

Nick

[miller]

What is neutral, is there any such thing when it comes to alcohol.  Having tasted more vodkas than I'd care to think about some days, they all taste different.  To be truthful it's very difficult to make exactly the same alcohol every time and blending hides a multitude of sins.  Lets not forget the water, the major part of vodka.  A few parts per million and the taste changes again.  The whole topic of neutral is nonsense, it's time to move on boys and girls.

[twadomikwadios]

I agree that the key word here is your interpretation of the word 'distinctive'. The government doesn't provide one so it seems reasonable to assume that it is up to the individual to decide. Distinctive to me suggests perhaps a  flavor, color or aroma that takes the beverage strongly away from the neutral flavor of vodka and into the realms of other products, thus causing confusion among consumers. If however your vodka looked like a whisky, smelled like a gin and and tasted like tequila, the TTB might not like that. However if it merely contains notes or subtle hints of the underlying distilled base then that would not count as 'distinctive'.

Normally, we apply this rule strictly to flavor, but I wonder if anyone produced an ever-so-subtly colored vodka (perhaps the result of very brief aging) what the reaction would be? Cat among the pigeons methinks.

IMO, of course.

[Seminole]

I am new to this forum and this is my first post. What do you call vodka? Well, I will call any dry 80 proof spirit a vodka. I drank a lot of vodka in Poland some 50 years ago and I drank some more this year. I went for 6 months vacation. By that definition a gin is juniper flavored vodka, calvados brandy is distilled apple vodka and a regular brandy is a distilled grape vodka. Then, we have dozens of great vodkas made from berries like Rowan (Sorbus aucuparia), Dogwood (Cornus mas) known as Cornelian cherry or Blackthorn (Prunus spinosa) also known as sloe. Rowan vodka (known in Poland as Jarzebiak) has been made and sold in Poland for centuries. In my opinion and some of my friends, nothing beats the flavor of Dogwood vodka.

Going back to plain neutral vodka I make my own standard: it is either good or bad. The bad is a typical moonshine made from sugar, the good one, well here it gets complicated, The superior vodka is the type that one can drink plain and one does not need a chaser. It should not leave a bad after taste and you should not shake your head. Does vodka like this exist. Yes, I have drunk it a few times, strangely enough it was not made by the factory but in a reflux distilling column at home. A guy used fermented sugar mash, the head and the tail were discarded, and 190 proof spirit went through a filter. Then, it was diluted with water to 82 proof and was run again through a filter. The spirit was left for one day and the next day it was perfect.
I believe the quality of vodka depends largely on the neutral spirit it was made from. In other words you dilute neutral spirit with quality water and you get neutral vodka. Polish Wyborowa was made from 192 proof alcohol, most great vodkas are made from 190 proof. There are many vodkas that are made from 180 proof spirit and that will leave a distinctive taste.

What came as a surprise to me was that in the past a great number of fruit vodkas were not by distilling flavored alcohol, but by mixing fruit infusions, extracts, sugar syrup and 190 proof alcohol together. Small amount of water was added to bring the spirit to the desired strength. Such vodkas usually needed some sugar and spices, for example sour cherry, or cranberry will not taste well without any sugar at all. I have made plenty of those and they were great. One of the favorites in Poland and Lithuania is honey vodka known in Poland as Krupnik and in Lithuania as Krupnikas. It may contain honey but a good Krupnik is 90 proof strong. Is it sweet, it is. But it is still a sweet vodka. If you add more honey or sugar to it then it can be called a liqueur.

Someone might ask why don't manufacturers produce those drinks anymore? A poor imitation of Krupnik is still produced, infused alcohols need space, containers, shaking and at least 3 weeks maceration time. It is too expensive, but you can make it yourself. I have just made 30 bottles of different vodkas and liqueurs for Christmas, no kidding, have photos to prove it.

[seventh son]

The first definition of distinctive is:
1.serving or tending to distinguish (Collins English Dictionary)

Therefore, you should be able to do a testing of every commercial vodka and not be able to tell any of them apart by taste aroma or color. If you "distinguish" any from another, then by definition it cannot be called vodka.

Now lets look at the real world. In practice, distinctive is applied as a subjective term. It seems to be more of a range than an absolute. Where the edge of that range of character and aroma lies is the real issue. There are those who strive for pure neutrality, and those who push the envelope of flavor and character. The beauty is that there is a place for both in the market.

[cowdery]

Fact: TTB does not have an organoleptic lab to test for neutrality.

[John McKee]

cowdery, on 12 December 2012 - 05:34 PM, said:

Fact: TTB does not have an organoleptic lab to test for neutrality.

...but they do have outside labs that perform the testing for them, for about $50 a test.  

  For new distillers contemplating this business, don't assume that because the TTB concentrates primarily on the "protection of revenue" that they don't follow through on the standards of identity, proofing & gauging, bond size, or auspices of their responsibilities.  They do.

Cheers.

[cowdery]

While I agree that people shouldn't assume they don't, I'm not so sure they do. Who has been asked to send a sample of their vodka to TTB for an organoleptic test of neutrality? Or of any product for any reason?

[Spazsquatch]

Can someone explain how any definition makes sense in a world with bubble gum flavoured vodka? Is the definition that there is no character beyond the flavouring offered on the bottle?

Hypothetically, could someone produce a 51% corn, barrel aged spirit outside the United States and call it "Bourbon Flavoured Vodka"?

[cowdery]

'Flavored vodka' and 'vodka' are different categories with different definitions. The TTB definition of 'vodka' applies only to 'vodka' with no modifiers.

As for your hypothetical, anybody can produce anything they want, but they can't sell it in the USA with the word 'bourbon' on it unless it is made in the USA and meets the TTB definition for bourbon.

[cowdery]

Another question is the relationship between the definition of 'vodka' and the definition of 'neutral spirit' or 'alcohol.' The vodka definition seems to define it as alcohol that has been filtered or otherwise treated, but it's pretty vague as to the distinction between neutral spirit/alcohol (which are deemed to be synonymous) and vodka..

A couple of months ago, TTB blew the whole question of neutrality out of the water when it decided Jack Daniel's Tennessee Rye should be labeled 'neutral spirit,' when it is nothing of the kind (distilled at 75% abv). Nobody is saying anything right now but it will be interesting, if the product is released next month as scheduled, to see if it's still classed as a 'neutral spirit.'

If it is, TTB will have created a loophole any clever distiller can drive a bus through.

For the story to date (the date being late October), go here.

[Edwin]

Looking at the originals of vodka in Poland and Russia, these are drinks that definately have taste. Not much, but more than just mouth feeling. If you carefully observe, you can distinguish between the potato, rye or wheat ...

I tried some "American defined" vodka's (neutral) and a perfect neutral (to me) tastes off.

Vodka's are originally pot distilled. Triple distilled mostly. I like mine with some taste left.

Edwin.