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kkbodine

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Everything posted by kkbodine

  1. Thanks for your detailed explanation.
  2. Interesting discussion and very relevant to a label I'm working on and about to submit. One point @dhdunbar "My take on this (and it is mine, not TTB's) is that a whiskey distilled from 51% or more of malt at 160 proof or less, stored in used oak containers at 125 proof or less, and bottled at not less than 80 proof, is, under the standards of 5.22(b)(2) "Whiskey Distilled From Malt Mash." The class is whiskey, the type is whiskey distilled from malt mash." Looking at CFR 5.22 I don't see where it says "stored in used oak containers at 125 proof or less". It certainly says that for other types but not specially in the section defining whisky from X mash. "(2) “Whisky distilled from bourbon (rye, wheat, malt, or rye malt) mash” is whisky produced in the United States at not exceeding 160° proof from a fermented mash of not less than 51 percent corn, rye, wheat, malted barley, or malted rye grain, respectively, and stored in used oak containers; and also includes mixtures of such whiskies of the same type. Whisky conforming to the standard of identity for corn whisky must be designated corn whisky." Is there another relevant section?
  3. kkbodine

    STATES REGULATING BARREL AGED COCKTAILS

    Yesterday I was working on the bottling line and wondering aloud about aging on a boat and Jefferson's in particular. It seems to be a clear violation of the regulation cited... I'm not sure if I'm over it or not. Edited to add: Anyone out there have a copy of one of Jefferson's ocean aged COLA's? My searching produced nothing but maybe I'm just lousy at searching today. Another edit: I found one of their COLA's and it shed no light on the topic other than being "bottled by"
  4. kkbodine

    proofing spirits proofed with sugars

    They will take samples and send them to their lab.
  5. kkbodine

    5110.28 Processing Report - partial case

    If you are bottling into actual bottles you should be using the bottled column. So yes it should all go together under "bottled". It is all about proof gallons; case/bottles should be added up appropriately and translated into PG.
  6. kkbodine

    5110.28 Processing Report - partial case

    You have made this way more complicated than it is. The proof gallons bottled should have gone on line 9 and line 28 co. b the first month. This report is all about proof gallons, case/bottles don't matter really. In succeeding months, the bottled inventory carries forward on the part II side of the form. As new products are bottled their proof gallons get added to part II from part I and usually you will have nothing left on line 26. As products are removed from bond, line 33 col. b most likely, their proof gallons are subtracted. In my opinion, you should re-submit the first report correctly as an amended report, top right of form. Then onwards from there. Message me if you want.
  7. kkbodine

    White Whiskey

    Thanks for that.
  8. kkbodine

    White Whiskey

    Note the "2" on "Whisky" According to that note at the end of the chart: "²Sufficient as class and type designation ONLY for whiskies made by: --Blending two or more specific types of whiskies, e.g., a blend of rye whisky and corn whisky should be designated “Whisky” OR --Treating with harmless coloring, flavoring or blending materials* a specific type of whisky not customarily so treated, e.g., bourbon whisky treated with caramel should be designated “Whisky”" So if we assume the TTB is following this as a labeling guideline (and a distiller is following this rule), using the word "Whisky" as the class/type of product is limited in a way but also opens up some potentially interesting whisky varieties and treatments (for those so inclined). Coming back to age, the BAM is very clear. The actual underlying regulations I can find aren't clear though I would assume that the TTB would follow the BAM guidelines because they have created them as a guide for labeling. Anyone know where in the CFR it says anything about whisky aging 4 years? I'm guessing it is carefully hidden.
  9. kkbodine

    White Whiskey

    That answer from the TTB makes no sense and seems like a very loose interpretation of the word "aging".
  10. kkbodine

    Head distiller for brand new startup

    Looking to get hit with an age discrimination lawsuit?
  11. kkbodine

    Craft is Not a Commodity

    The wine industry has stressed local and terroir, or at least called out product origin, for a long time; with limited ways to obfuscate. Beer has been getting a pass on using local. The beer industry is a way behind in sourcing local ingredients and most "craft" brewers use nothing local; it simply has not been an issue. The resurgence in local hops seems more driven by market opportunity for farmers than any real call by beer consumers. Owning both a winery and a distillery I see a vast range of consumers. People who know anything about the business or understand the information on a label are few and far between so it is a constant educational process. Most days it comes down to taste and price; local is a nice to have for some people, most don't care. A frustrating reality to those that do care. The local food movement is very strong in my area and a few other areas of the US so some of that is spilling interest over. I actively encourage people to read and understand labels; though servers in tasting rooms can get away with all kinds of lies without repercussions. Of course one can also walk into any place that sells alcohol and find labels that the TTB should never have approved.
  12. kkbodine

    Blending Our Vodka and NGS Labeling

    Well if you believe this article from Forbes (2013) then yes. https://www.forbes.com/sites/meghancasserly/2013/06/26/haunted-spirits-the-troubling-success-of-titos-handmade-vodka/#6f12b33312c9 "Tito's has exploded from a 16-gallon pot still in 1997 to a 26-acre operation that produced 850,000 cases last year, up 46% from 2011, pulling in an estimated $85 million in revenue."
  13. kkbodine

    Finished Product Storage and Exemption

    I'm curious, what were their concerns about the open fermentation?
  14. kkbodine

    special bulk orders with special sizes/volume

    Some non-specific advice: As a general rule whatever you sell is going to have to go through all the normal channels. If you can legally sell directly to the public or a bar then fine, but labeling rules will still apply. I don't know if in New York a distillery can sell directly to a hotel (I'm assuming the hotel bar in this case), I can't in Maine, but having dealt with other states I would bet that price posting will be required. NY regulators should be able to answer that quickly.
  15. kkbodine

    Assistant Distiller at Estate Distillery

    To me the "Essential function and Responsibilities" section is asking for a lot at the assistant level. The education and experience seems wanted seems fine but might be difficult to find given how young/small the industry is; though they are not limiting it to degrees/experience in distilling. In the wine industry, assistant winemakers would easily have that level of education and experience, would usually be educated in winemaking (BS), and some would have a master's degree. Of course wine is a bigger industry in terms of numbers of companies with a longer recent history.
  16. kkbodine

    At what point is a pot still too big?

    Jameson has some pretty huge pot stills; Wikipedia says they are 75000 L. My family and I toured the working Midleton distillery in early 2011 but I can't remember how big they said they were. I do have a picture though which won't upload for some reason. Of course they are a massive company... Picture here (maybe) https://ibb.co/hCRpda
  17. I think you were given two wrong pieces of information. Your state might have some weird alcohol permit requirement but I don't believe the TTB makes a distinction. You will need a transfer in bond form filed with TTB for anything brought in from another DSP. Maybe that is what the guy on the tour meant?
  18. kkbodine

    Transfer in bond to Winery

    Off the top of my head I'm going with no. Wineries can only typically use grapes, fruit, honey, cane sugar, grape brandy, fruit brandy, grape concentrate, et al so something like GNS or whiskey would not be allowed. And anyway, a soda cocktail product made with some random alcohol cannot be done by a winery as far as I know. They need to investigate that idea a little more I think.
  19. kkbodine

    Selling spirits in bulk quantities

    As far as I know, from the federal standpoint you just have to pay the tax and report the withdrawal on the appropriate monthly reports. Your state may have some rules about who can sell, transport, and/or receive bulk tax paid alcohol so check with them. I would create a label for the drum that states your company name, DSP #, address, type of spirit, proof gallons, wine gallons, and whatever else seems logical. There may be federal requirements somewhere in the regulations but that is what I have typically seen. We gave up producing vanilla extract for the past two years as vanilla bean prices have been very high.
  20. kkbodine

    Do I need to be a Mad Scientist?

    I agree. They show that he could complete something and most likely has critical thinking skills.
  21. "Now hold on, because the rest of this is going to blow your mind." Mind not blown. I hear essentially the same story multiple times per year from people who dream and talk but never do a damn thing.
  22. kkbodine

    Do I need to be a Mad Scientist?

    I try not to be rude but sometimes people will show up on a super busy day or during an event and expect full attention/lots of time and that is difficult.
  23. kkbodine

    Do I need to be a Mad Scientist?

    I'l probably get blasted for this but... I get a never ending parade of people wanting to apprentice or work for free to "learn the craft". Basically you are asking to get for free what has taken me 25 years and a masters degree to acquire. So unless you offer some skill I happen to need or I'm short on bottling labor, I'm not super inclined to take your offer. In fact my standard response is to offer you training at $1000 per day; you pay me. Most small operations don't need any body, they need skilled bodies; we simply aren't big enough to afford the luxury in time or money. If you can't find a position in a distillery, try a brewery or winery to get a good feel for what we do. Which, by the way, is mostly cleaning. A science background is not absolutely required but it helps when problems arise. In a small operation, being able to handle any situation with creativity is key. Can you re-wire a pump or tweak a labeling machine? Mechanical aptitude often saves the day. Just having passion, or what you think is a good idea, does not make things happen; you must be able to follow through. I don't want to discourage you, but unless you bring some skill, most operations simply don't need you. End of rant.
  24. kkbodine

    Transfer Spirits FROM BW -to- DSP?

    I can't imagine that TTB would really like that arrangement as the winery would be acting as a distillery. There really isn't a line on the form for the transfer other than the blank line 7 so it would seem to be an operation that is meant to be uncommon. Or maybe they just didn't think of it.
  25. kkbodine

    Transfer Spirits FROM BW -to- DSP?

    We aways use any spirits transferred into our winery right away so I don't even carry over inventory; I figured there would be a solution as it must have been an issue at some point. Glad I could help and was actually right.
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