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bluestar last won the day on September 4

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About bluestar

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    Chicagoland & Southwest Michigan

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  1. Topping off barrels

    Unfortunately, that is something of a non-answer. Specifically, you don't indicate the maximum amount of water you may add. The cited TTB ruling is specifically calling out the ability to add harmless materials (water in this case), that would typically be added in production or processing (not storage) for the type. But for that ruling to apply, the amount added must be less than 2.5% volume. So maybe they are trying to say you can add 2.5% water and not require a formula, because it will still be whiskey. Which begs the question, what if we add MORE than 2.5%, since then the TTB ruling would not apply?
  2. Blending Our Vodka and NGS Labeling

    Hmmm. There might be a reading of this that is in between. Dhdunbar is correct, you will need to submit a formula if you buy or make NGS that is not designated as vodka at the time of production, and you want to change it to vodka. And two ways to do that is to redistill it or filter it as explained in 5.27 (and you will need a formula approval for the TTB to determine the final product is vodka). Interestingly, item no. 3 in section 5.27 (l) suggests a third alternative: mixing with anything other than water (which won't change classification and type). That could be mixing NGS from one source with another, or maybe with a mouth-feel additive like sugar or glycerin. Then you will have to submit a formula to prove to the TTB the resulting spirit meets the requirements for vodka. That might require you to provide specifics on how the NGS was made, to essentially show that its method of manufacture assures a product that could have been classified as vodka, but wasn't at the time. But for you to say you produced, you have to do something to it beyond just repackaging it, which would be bottled by. But this does suggest, that contrary to dhdunbar, maybe you could mix your distilled vodka with purchased NGS and call it vodka, if you submit a formula for approval that describes the NGS and possibly how it was made by its source, so that the TTB decides the resulting product is vodka. It might be they won't approve. But perhaps this route is suggested by the CFR?
  3. private labeling, contract bottling

    Just rereading the CFR: actually, I think you don't have to indicate where it was bottled so long as the contents were otherwise produced and processed at the cited distillery. See section 5.36 (a) 2: where instead of saying who it was bottled by when bottled for a distillery, you need only say who it is distilled by, unless it was a Bottled in Bond whiskey. From my reading of that, you might not be able to do any rectification, meaning you might have to bottle it as received from the distillery?
  4. private labeling, contract bottling

    So it would say distilled by me, IL, and bottled XYZ, IA?
  5. Regional Differences for Aquavit?

    Swedes traditionally use a rye spirit base, and often include dill with the caraway (in fact, dill can be the dominant flavor in some styles), and usually don't barrel age. Danes may include some cumin with the caraway, Aaborg is known for including amber in one version, and can be barrel aged. The Norwegians specifically use oak for aging, often used sherry barrels, and age for longer periods than other countries. Other spices and citrus can be used as well, and varies by producer. Some add caramel coloring. We have done a Swedish style (rye based, with significant amounts of dill with the caraway, other brown spices), but long aged in used bourbon barrels.
  6. winery in distillery

    I know that setups were approved in years past that the TTB is more stringent about now. In particular, things like separations between brewery and distillery, or winery and distillery, or bonded versus general premises.
  7. Basic Amaro recipes

    Most are liqueurs, so they are not redistilled, they are extracts in spirit with sugar and other flavor and coloring added.
  8. How to keep cooling water from going bad

    FYI, Acid #5 is a mixture of nitric and phosphoric acids, with some detergent. It is rated for food processing use. It will passivate stainless. Must avoid contact with chlorine containing materials. Especially useful where regular detergent cleaning does not do a good enough job of removing organics, it will neutralize the akaline detergent like citric, but will also further work on any residual organics. While it should passivate stainless, it will continually etch copper or other etchable metals, so I am not so sure it is the best choice for adjusting pH for recirculation systems, unless they are all stainless.
  9. private labeling, contract bottling

    Joe, curious, if we send you our juice to bottle, and you send it back in bond, how do we have to label it? Clearly, I can say distilled by me. Do I have to say bottled by you? Can I simply say produced by me? Etc.
  10. Bourbon and rye for sale, 53g barrels

    Those seem like reasonable prices. Are they pot distilled whiskey done at your distillery? What char are the barrels?
  11. Topping off barrels

    Simple thought experiment: assume you are in storage, don't worry about it being in barrel. You have spirit in a tank at a given proof. You add water. You are required to gauge when you do this. In principle, there is no de minimis, so in the thought experiment you could assume something like adding 20 gallons of water to 1 proof gallon of spirit. A barrel, in addition to being the required vessel for aging, is also a storage vessel. So again, you would be required to gauge when you do this. You don't have to gauge when some "accident", such as leak, evaporative loss, angels share, devils cut, etc., changes things, until you remove the spirit from the vessel. Small amounts of sampling are also treated in this way, as an "accidental" loss, but larger draws would have to be at least recorded. So, at a minimum, you are likely to have to gauge if you were to add water to the barrel, recording the change in volume and proof. Unless there is something in the CFR that says you don't, which I can't find, at least not for whiskey. I do agree, you could read 19.326 to suggest you might not have to do this for brandy or rum, but of course, you would gauge if there were any transfer of spirits, at least to record what what was moved from where and to where. This concept that there is no de minimis shows another problem with addition of water: obviously, there must be a limit, since you could have 50%+ loss in angels share after long aging, decide to add water to refill the barrel (which is not whiskey going into the barrel), and the resulting proof will be so low in the barrel, the product would no longer qualify as whiskey. This is not spoken to anywhere in the CFR, and I assume that is in part because the CFR simply presumes this will not happen: you can not blend in something that is not whiskey with whiskey and expect the category and type to be the same. Even 19.326 probably assumes you won't do that, but rather will top off or blend like spirits (rum with rum, brandy with brandy), unless you are proofing down and gauging. This analysis also suggests that adding water, by virtue of the possibility of changing the category or type of spirit, would require a formula approval.
  12. Topping off barrels

    The definition of age is the period of time the product spends in barrel (section 5.11, "Age"). If you add water to the distillate in barrel, one or both of two things must be true: the product is now the old distillate with the water added, which is a new product, and the clock starts for that product to age in what is now a used barrel; or you have "rectified" the product by adding water, and the clock stops in that barrel. The point being, the product before and after water is added is now no longer the same product, it would need to be gauged and reentered in the records, as would any distillate anyway along the way of production or processing. When in storage, the product can not be altered, at least not intentionally. Another way to think about it is that the water added, or anything added, has not spent the time up until that point in the barrel, and has not aged to that point. Hence, the contents of the barrel are now a blend of aged and unaged product.
  13. Distillery in Malt Plant

    Of course, each TTB reviewer will give their own opinion, but we had extensive discussions about using the distillery for non-distilling activities, and in the end, they convinced us that we had to not only separate bonded premise from general premise, but that there needed to be a separation between general premise and non-distillery space, although it did not require the same level of security as the bonded premise. In the end, this makes sense, since you are required to report the acceptance of the malt into the distillery for production as a separate activity from malt being sold outside or used for another purpose. Similarly, any grains brought into the distillery would have to be reported on your production report, and that becomes ambiguous if the grain might not be used for distillation. The reporting and tracking of raw materials brought onto distillery premises and its security is part of how the TTB assures you are not "cheating". Now, I would presume you could sell malt from the distillery, but to do so, you would have to report all the grain coming in and all the malt going out somewhere in your monthly reports. Otherwise, you would have to show a way that you physically separate the malt and grain accepted for production, so that only malt used for production goes into the monthly report.
  14. Distillery in Malt Plant

    And you are selling malt to others?
  15. Topping off barrels

    For US, clock stops with any addition to the barrel.