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dhdunbar

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dhdunbar last won the day on February 20

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    Eclectic - from square dancing to Miles Davis; browsing the library for books of interest - Tony Hillerman crime novels to popular books on quantum physics. Simply sitting. Cooking dinner when someone else will wash the dishes. Walking the dog. Poetry and epistemology. Writing.

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  1. Warehousing, aging spirits

    Falling Rock - that is what I mean by "be generous."
  2. Final proofing documentation for TTB

    Whoa - I misread this the first time. I bet you mean the proof and fill check you make at the time of bottling. I'll talk about that here. I wish I could do it in a few short words. I can't. The law says TTB must make regulations that make sure consumers are not misled as to the quantity of the product in the bottle. For spirits, the quantity is the volume, but it is also the proof. So TTB requires that you tell consumer how much and how strong. Because TTB is not making tests to determine if you are doing that, they require that you keep records to prove that you are. It sounds good in theory. It sounds professional. But it is not. Your records will not provide assurance of compliance. Let’s look at why I say that. The regulations provide for a record of the proof and the fill of bottles. You find the record requirement in 19.600, which is headed "Alcohol content and fill test record." It requires specific information, but you will not find a "form" that TTB offers as appropriate for your use. In the broad sense, the records you keep of the tests you perform for each bottling are supposed to allow a TTB official to determine that you are complying with Sec. 19.356. Sec. 19.356 requires that, during bottling, you take adequate samples of bottled spirits, at representative intervals, to "ensure" that products are within the tolerances established by that section. I add the emphasis to point out TTB doesn't tell you how to do what they require. The regulations do not discuss how many samples you must take and at what intervals you must take them in order to "ensure" compliance. They place the onus on you. Why doesn’t TTB give sample sizes and frequency? It doesn’t do that because it is impossible for you to do what they ask. Sampling is not an easy subject and I am not an expert. I know just enough to recognize hogwash. It is hogwash to expect any small distiller to have a sampling program that “ensures” compliance. It also is hogwash to expect any small distiller to have a sampling program that will allow statistically valid projections of compliance at any reasonable confidence level. If pressed about sample parameters, the TTB officer who is auditing your records would probably dance to the side with a comment, every case is different, so we can’t specify sample size. Well, sure, every case is different, but the rules for statistical sampling, i.e., for sampling from which the TTB officer can draw the conclusion required by 19.356, that the sampling program ensures compliance, don’t change. And that leads to problems. The basic rules of statistical sampling do not allow for a sampling program that will ensure compliance. Talk of ensuring is prattle. Since TTB cannot possibly create a sample standard that ensures, it punts. TTB says it is up to you to devise the program. Going a little deeper. If we want to draw a conclusion from a sample, we must know the sample size needed to establish, within an acceptable degree of accuracy, that the bottles are consistently within the tolerance established by 19.356. Assuming you select the sample in a valid way, given the sample size, the frequency of the sample, the expected error rate, and the universe from which it is obtained, you will have a level of assurance, say 95%, that between 96% and 98% are within the tolerances allowed. Note that it is a qualitative finding. It says nothing about how much things vary. An error of 5% counts just as much as an error of 50%. All errors are created equal in frequency sampling. Which is fine, as far as theory goes. But when the universe is small, i.e., the size of a bottling run by a small distiller, no sample size will provide results that will allow a conclusion of the sort, we are 95% sure that the between 96% and 98% of the bottles were within tolerance. Even if TTB were to have a standard that said, you must take sufficient samples to establish, with a 95% confidence level, that between 96% and 98% of the bottles were in tolerance, TTB would have to determine how taking stratified samples, instead of random samples, affect the assurance of compliance, what rate of error is expected, etc., i.e. how to deal with all the variables that bedevil students in college statistics classes, let alone a small distiller left adrift by broadly stated requirements for which TTB provides no further guidance. Worse yet, in a small business, audit standards provide that an auditor looking at compliance must assume that the internal controls are inadequate to ensure. And proof and fill tests are "internal controls." Because the auditor cannot place any reliance on internal controls (you could be inventing all the test data), the auditor would have to test every bottle to ensure compliance. But most of those bottles had best be gone from bond or your business is probably in deep trouble. My point? Sampling is not an easy subject and I am not an expert. I know just enough to recognize hogwash. It is hogwash to expect any small distiller to have a sampling program that ensures compliance. So, what would I recommend, recognizing that I am not TTB, but that TTB has chosen to punt? The practical answer is, provide the TTB officer with information that satisfies the TTB officer, who, like you, is without an objective standard for how many and how often to test. I know, that is a statement of the obvious, but it is all we are left with. My best advice, in practice, is ask yourself, based on your sampling, if you are reasonably sure that you are within tolerance. If you are reasonably sure and the TTB officer is a reasonable person, your program will pass the test. That is the best guide I can offer. I'd be interested in hearing comments from any statisticians and/or auditors on my comments.
  3. Final proofing documentation for TTB

    The regulations (19.618 for other than packages and 19.619 for packages) require a gauge record for any of the required gauges specified. You can see the information that record must contain. Did you know, for example, that it is suppose to contain the proof of distillation? Well, it is. However, the gauge record section does not answer how you record, for posterity, the elements of the gauge. Obviously, the elements of the gauge are different if you determine the wine gallons by weight or by volume. By volume, you have two corrections: one for the built in error of the certified thermometer - for which you have a correction table, of course - and one to correct to the volume at 60 degrees H. For hydrometer readings, assuming you do not have one of the expensive density meters that TTB accepts, you need the correction for the variance from apparent proof that is intrinsic to the instrument, and for the correction to 60 degrees F. If you know how to use the tables in the gauging manual, it is easy to prepare a temple in Excel with formulas that allow you to enter the apparent readings and table values and convert the apparent readings to actual readings. Some people sell apps for doing that, but I've not checked them out. TTB provides a handy proofing worksheet with the package it sends when it approves an application to establish a DSP. It doesn't come with instructions, but it shows what they would like to see: Append one of those to each serially numbered gauge record, or to other records, hen no gauge record is required under 19.618 or 19.619, and you will have done everything TTB might require in its wildest dreams of compliance.
  4. Warehousing, aging spirits

    Ask TTB. I'm serious. They won't be able to tell you. Yes, it is information required by the regulations, but how did that come to be? I don't know. I'll guess. If you are going to establish a DSP FOR STORAGE ONLY, i.e., no production or processing, if it has a capacity to store less than 250K wine gallons, you have to ask TTB's permission. That is the only provision that I find relevant to the wine gallon capacity and I know my way around part 19. So ... make what I would call a SWAG - a scientific wild ass guess. And be generous. TTB doesn't want you to have to amend an application over such matters any more than you want to have to do so.
  5. You do not need to include, in the equipment list, any portable bulk containers having a capacity of less than 101 gallons. Sec. 19.75 Major equipment - As required by Sec. 19.73(a)(9), the application for registration must include a list of the major plant equipment. If the equipment is set up and used for the production, storage, or processing of distilled spirits, wine, denatured spirits, or articles, the list must provide the following information: (a) The serial number and capacity of each tank in the plant. The list does not need to include any bulk containers having a capacity of less than 101 wine gallons on the plant premises if those containers do not meet the criteria of a tank under Sec. 19.182 (perks, small totes, etc.). The only problem with that is that 19.182 does not contain criteria for determining if something as a tank. It contains requirements for how you must equip a tank if you have a tank, but it does not say what a tank is.
  6. Mashing Off Site

    You do not need to pitch the yeast. Section 19.296 authorizes you to receive beer from persons who are qualified as brewers. Let's assume you get beer. As Bluestar says, there is a difference between the requirements for beer and wine and it has to do with when tax attaches and thus, as he says, to the bonding requirement. You won't find any guidance on receipts of beer under the provisions covering receipts in bond. The reason is simple enough. Wine is in bond, but beer is not. It is not in bond because the tax does not attach - and this is for beer only, not wine or spirits - until it is removed for consumption and sale. A removal for consumption or sale is any removal that is made except those made without payment of tax. Removals to a distillery for use as DM are removals without payment of tax. All of that comes from part 25, which also requires that the brewer make a record of removals without payment of tax that show the date of the removal, the quantity removed, and the person to whom it was delivered. That is all the regulations say the brewer's record must show. Let's close that book and turn to part 19. Since the beer is not in bond, you will not find any guidelines in the provisions of part 19 related transfers and receipts in bond. Look instead for the term "fermented material." That leads you to 19.296, which simple says you can receive beer from a brewery. [If you receive unfermented grains that have been cooked, it is treated as a receipt of fermenting material, like corn, and reported in gallons, not pounds. But let's go on assuming it is beer.] The DSP production record requirement is in 19.584. It requires only that you make a record of fermented material (beer or wine) that you receive. it provides no detail of what the record must show. It is easy to assume it means gallons, especially in the light of the daily record requirement at 19.581. That section requires a daily record showing, for materials intended for use in the production of spirits, the kind and the quantity, with liquids recorded in gallons, as Bluestar says. Next, 19.571 includes, as records you must keep, "all supplemental, auxiliary, and source data that a proprietor uses to compile required forms, records, and summaries, and to prepare reports ..." Part 25, the beer regulations(25.291), requires that the brewer to make a record of removed without payment of tax. The record must show the date of removal, the person to whom it was shipped, and the quantity. That is all. So this seems to be a very simple sort of accounting. Who sent it to you, when did you receive it, and how much was it. So much for what the regulations say explicitly about what the records must show. Now let's get wonky. What is not said is probably more important. The records you must keep as a distiller must show the kind of spirits you produce, as do the operating reports, and, oh yea, the labels on the bottles. Compliance requires that you must know what materials were fermented to make the beer. If you did not ferment the materials, then the brewer must tell you the materials from which it fermented the beer (yes, this is also true of wine). For example, we all know that the class whiskey = all grain, and that the type bourbon must be 51% or more corn. You cannot know if you have bourbon unless you know the mash was produced from 100% grain, of which 51% or more was corn. You can assume 100% grain because it came from a brewery, which must use only grain. But what about the grain bill? Make sure the record you receive from the brewer contains more than the minimal information required. Make sure it is sufficient to demonstrate that the product is indeed bourbon or rye or malt whiskey, is you are going to show a class and type. Think about the possible consequences of not being able to prove that the spirits in the bottle labeled as bourbon meet the standard of identity for bourbon. Remember, you may loving age it for three years or more, i.e,, beyond the period for which a brewer must maintain records covering the beer he sent you as DM. Write him to ask, after the three years has expired, and he might reply, I don't have those records any longer. Where are you then? I went wonky, but end up with a potentially knee breaker.
  7. TTB Gauging Table 4 has a mistake

    Good catch, but they know it. The gauging manual contains the following: § 30.64 Table 4, showing the fractional part of a gallon per pound at each percent and each tenth percent of proof of spirituous liquor. Table 4 [TTB editorial note: Erratum on page 549, Proof of 173.7 proof should read Wine gallon per pound of 0.14233] I didn't know that until I started poking around. The tables have been around since dirt and I figured someone had to have caught this before. They had. TTB should update the tables, but ...
  8. TTB's regulations provide (Sec. 19.409 ) A proprietor may withdraw from customs custody spirits imported or brought into the United States in bulk containers for transfer of those spirits without payment of tax to the bonded premises of the proprietor's distilled spirits plant. The proprietor may receive these spirits either in bulk containers or by pipeline. Spirits received on bonded premises under this section may be: (a) Withdrawn for any purpose authorized by chapter 51 of the IRC in the same manner as domestic spirits... Again, I know little about the Customs regulations and am not even confident that I can figure out the questions to ask. I suspect that the manipulation in a CMBW or other customs facility is going to be cost prohibitive. "Suspect" is a carefully choshen word. I use it because I simply lack knowledge. Also, I am not sure of the manner in which Customs uses the word duty. A quick Google search of "transfer of distilled spirits from Customs to Internal Revenue Bond leads to: § 141.102 When deposit of estimated duties, estimated taxes, or both not required. Entry or withdrawal for consumption in the following situations may be made without depositing the estimated Customs duties, or estimated taxes, or both, as specifically noted: (a)Cigars and cigarettes. A qualified dealer or manufacturer may enter or withdraw for consumption cigars, cigarettes, and cigarette papers and tubes without payment of internal revenue tax in accordance with § 11.2a of this chapter. (b)Bulk distilled spirits transferred to the bonded premises of a distilled spirits plant. An importer may transfer distilled spirits in bulk to the bonded premises of a distilled spirits plant, without the payment of tax, under the provisions of section 5232(a), Internal Revenue Code of 1986 ( 26 U.S.C. 5232(a)), and the regulations of the Bureau of Alcohol, Tobacco and Firearms ( 27 CFR part 251). The reference to ATF, instead of TTB, dates the regulation, but it may be a simple housekeeping matter that has not been resolved. The phrase "estimated Customs duties, or estimated taxes, or both" implies that the duty is different than the tax, but .... IRC regulations [19.223(e)] go on, "[W]hen imported distilled spirits in bulk containers are withdrawn from customs custody and transferred to the bonded premises of a distilled spirits plant without payment of the tax imposed on imported distilled spirits by 26 U.S.C. 5001, the person operating the bonded premises of the distilled spirits plant to which spirits are transferred will become liable for the tax on the spirits upon their release from customs custody, and the importer will thereupon be relieved of liability for the tax. So, I know you do not pay the taxes upon transfer from customs to IRC bond,, but whether a separate duty is due, I don't know. As you can see 19.409, which I quote above, if you transfer from Customs to IRC bond, the spirits are treated in the manner of domestic spirits that are held in bond. That means that the tax is not due until you do something that triggers the liability, and removals from IRC bond for export are done without payment of tax. They are not tax free, which means that you remove them without payment, but before you are relieved of the tax, you must prove the exportation, which occurs if you deposit them into a customs bonded warehouse or have them ladened onto a ship. There are rules that cover the relief. Hopefully, this bit of free advice gives you a place from which you can start to pursue the alternatives. Send me a personal message if you would like me to pursue this further, since it will take some time to do so, which comes under the heading, "That's my business :-)."
  9. Well, you have hit upon an esoteric enterprise. When you get involved with import and export, you always want to deal with Customs through a customs broker. Period. I consult for distilleries and I would never say that you always, or even usually, want to use the services of someone of my ilk when dealing with TTB. It is not necessary. When dealing with Customs, it is. Did I say, "Period?" I am not competent to comment on your question, at least not in detail. I will refer you, instead, to a Customs' webpage that discusses their bonded warehouses. They come in a variety of flavors. See https://www.cbp.gov/sites/default/files/documents/bonded_20wh2_2.pdf. Two of those flavors are described as follows: 6. Bonded warehouses established for the manufacture in bond, solely for exportation, of articles made in whole or in part of imported materials or of materials subject to internal revenue tax; and for the manufacture for domestic consumption or exportation of cigars made in whole of tobacco imported from one country; and 8. Bonded warehouses established for the cleaning, sorting, repacking, or otherwise changing the condition of, but not the manufacturing of, imported merchandise, under CBP supervision, and at the expense of the proprietor. I know just enough to be dangerous. Contact a customs broker for reliable information. I'd also be interested in knowing why you would not simply import it in bulk into the DSP, then remove it for export without payment of tax once it is bottled? Those are transactions of which I do have some knowledge.
  10. TTB Labeling Requirements for Non-Potable Bitters

    I've been too busy to look here much lately. Nonbeverage bitters are not covered by TTB labeling requirements. They are covered by the FDA labeling rules for foods. You may not make nonbeverage products on DSP premises (19.344(b). See also the definition of eligible flavors at 19.1. You may alternate DSP premises to premises for the production of eligible flavors (`19.143(a)(4). The rules re the manufacture of nonbeverage products are not found in part 19. See part 17. Basically, the DSP pays the tax on the removal to the nonbeverage facility, and the manufacturer then claims a drawback of $1.00 less than the tax rate (which makes it $12.50 a pg) for all products made under a formula TTB has approved for the product manufactured.
  11. Can we ship bottles to customers?

    You've got to know two laws - the law of the state from which you are shipping AND the law of the state into which you are shipping. Because it is a big wine state, California makes special dispensations for brandy. It does not follow that Iowa will do the same.
  12. I'll take a look at this through the regulations. The BAM is good, but it does not get down to how TTB makes decisions, so it is not of a great deal of use in deciding how to frame issues if you would like to get a change. Tom Lenerz, and perhaps others in this thread too, is correct. Vermouth is a wine in TTB's eyes and therefore you make it on winery premises, not DSP premises. It is a separate qualification. To call it vermouth it has to fit the standard stated above. Next, the spirits labeling regulations (part 5) define distilled spirits and the definition makes reference to wine. A distilled spirit is "Ethyl alcohol, hydrated oxide of ethyl, spirits of wine, whisky, rum, brandy, gin, and other distilled spirits, including all dilutions and mixtures thereof, for nonindustrial use. The term “distilled spirits” shall not include mixtures containing wine, bottled at 48 degrees of proof or less, if the mixture contains more than 50 percent wine on a proof gallon basis." Thus, one can extrapolate to a rule, "The term distilled spirits shall include mixtures containing wine, including mixtures bottled at 48 degrees of proof or less, if the mixture does not contain more than 50 percent wine on a proof gallon basis." That blows the 2.5% limit out of the water except where the standard for the class and type impose a limit of not more than 2.5%. For example, Class 8, Cordials and Liqueurs, has a type "rye liqueur (and other whiskey types) that states, "(2) “Rye liqueur”, “bourbon liqueur” (rye, bourbon cordial) are liqueurs, bottled at not less than 60° proof, in which not less than 51 percent, on a proof gallon basis, of the distilled spirits used are, respectively, rye or bourbon whisky, straight rye or straight bourbon whisky, or whisky distilled from a rye or bourbon mash, and which possess a predominant characteristic rye or bourbon flavor derived from such whisky. Wine, if used, must be within the 21/2percent limitation provided in §5.23 for coloring, flavoring, and blending materials. The 2.5 limitation in section 5.23 addresses whether the additions of harmless coloring, flavoring and blending material, to which Silk City and perhaps others too, mentions. changes the class and type. Some do; some do not. 5.23 provides, in pertinent part, "(2) There may be added to any class or type of distilled spirits, without changing the class or type thereof, (i) such harmless coloring, flavoring, or blending materials as are an essential component part of the particular class or type of distilled spirits to which added, and (ii) harmless coloring, flavoring, or blending materials such as caramel, straight malt or straight rye malt whiskies, fruit juices, sugar, infusion of oak chips when approved by the Administrator, or wine, which are not an essential component part of the particular distilled spirits to which added, but which are customarily employed therein in accordance with established trade usage, if such coloring, flavoring, or blending materials do not total more than 21/2 percent by volume of the finished product." The customary use provision came into play when TTB decided whether the addition of wine to American type whiskey is allowed without changing class and type. That is another subject, but I thought I should mention it here, lest someone take a wrong way turn up a one way street. Those who look at the BAM have an advantage here, because prior to the ruling on general use formulas, there were no higher level documents that discussed the issue of why bourbon is treated differently from rye whiskey when it comes to the addition of harmless coloring, flavoring and blending materials within the 2.5% limit. If you do not have need to understand that issue (say you do not plan to "finish" bourbon in port barrels), do not wade into that pool. Finally, the specialty provisions apply because they give you the ability to create products other than those that conform to class and type designations. Here, the limits imposed by the definition of distilled spirits, where this post started, determine if you can label it as a spirits product.
  13. Can we ship bottles to customers?

    In a January 2016 document (I doubt much has changed since then) the National Association of State Legislatures stated (http://www.ncsl.org/research/financial-services-and-commerce/direct-shipment-of-alcohol-state-statutes.aspx):: The majority of states have statutory provisions that allow for out-of-state manufacturers to ship alcoholic beverages directly to consumers. The majority of states restrict the direct shipments to wine. Hedgebird provided a link to that web page previously in this thread. The question has evolved. It is now, "Can anyone who regularly submits products for competition, or an out-of-state industry event, a reviewer, or analysis tell us how they are shipping?" The NASL does not provide answers to that question. Its answers involve shipment made directly to consumers. Exceptions to the general prohibitions must be determined on a state by state, case by case basis. I don't know those rules and even if I did, I would not advise you on what you should do. The NASL provides some very good advice. It states, in bold letters in the original, "Please note the summaries should be used for general informational purposes and are not intended as a legal reference. NCSL is unable to provide assistance, give advice or answer questions regarding individual cases. If you have questions regarding the direct shipment of alcoholic beverages to consumers, please contact an attorney in your state or your state attorney general. This forum provides a great service when it discusses questions within the expertise of the persons who respond, e.g. "Why is my gin cloudy?" but when it comes to matters as legally complex as the interstate shipment of distilled spirits, we are in over our collective heads. Here is how I would approach the problem. If I wanted to send to a lab, or reviewer, or competition, I would ask the person to whom I propose to ship, for some citation, in the laws of the state in which they are located, that gives me permission to ship to them. Then I would verify it with the state. Importantly, FedEx is not, in applying its internal rules, the keeper of state regulation. If you register, etc, with FedEx, and they subsequently take a shipment from you, and it is not legal for you to make the delivery to the recipient named, FedEx is in trouble with the state, but so are you. "FedEx let me do it" is no defense. I suspect that there is not much danger in shipping to a laboratory. Reviewers and competitions are probably tricker. I asked previously, "What is your tolerance for risk?" I guarantee that the first question a state will ask you, if they discover what you are doing and take exception to it, is "Why didn't you first ask us?' Then comes, "Ignorance of the law is no excuse."
  14. Barrels and Aging / TTB Rules

    No age statement, for American whiskey (other than corn) = four years or more in oak of the appropriate type (new charred or used). Store anything in oak containers for less than four years and you must make an age statement. Those who bottle whiskey which has been stored in oak of the appropriate type for less than four year and do not make an age statement in the appropriate format are in violation of the labeling requirements. What people "may" do and what they "can" do are not the same. They may not omit label statements that are required, but they can do it if no one enforces the requirement. The NAS on Scotch and Irish are acceptable, but the products have a minimum age period that American regulation does not impose. You can label American whiskey with an age statement, "aged 32 nanoseconds," and comply. But if it is less than four years, you must use a statement of the form that says the product has been aged for not less than X units. See 27 CFR 5.40 and the standards of identity in 5.22. Age is defined at 5.11 - Age. The period during which, after distillation and before bottling, distilled spirits have been stored in oak containers. “Age” for bourbon whisky, rye whisky, wheat whisky, malt whisky, or rye malt whisky, and straight whiskies other than straight corn whisky, means the period the whisky has been stored in charred new oak container. The container must be made of oak. The CONTAINER must be made of oak. Sticking oak staves or chips in a barrel will not suffice. The CONTAINER must be made of oak. HOWEVER, and this is a big however, if the frame contains staves that line it completely, I can't see a problem. The container is an oak container with a metal frame replacing the metal hoops. As far as I know, no one has ever said that that the area of the hoops cannot exceed x% of the total area of the barrel. TTB may have ruled on metal heads in a way that is possibly revelvant as well. I note that adamOVD reports, "I recently [had] the opportunity to talk to them at a beer festival, and try some whiskey aged for 4 months. It tasted pretty similar to something aged in a 5 gallon barrel for 4 months. They said they are currently working on getting approved by the TTB to be able to use age statements." If true, it indicates that Sqaurebarrel is aware of some issue, or it may only indicate that they are dotting "i" and crossing "t's.' None of this, of course, speaks to the quality of the product that results.
  15. Barrel Aged Gin

    I can't advise you of what TTB will approve, but look at the Angel's Envy label on TTB's COLAs Online website. I would say that it is creative, on both the bottlers and TTB's part. TTB calls Angel's Envy a whiskey specialty. There are bourbon and rye specialty labels approved, something like 18 COLA's in all. Let's consider the label of one whiskey specialty - as TTB designates it - composed of rye whiskey finished in rum barrels. TTB considers "Angel's Envy" the brand name, and a statement, "From the Cellars of Lincoln Henderson" the fanciful name. TTB does not state what it considers to be the truthful and accurate statement of composition. But if we look at the information on the brand label, where the class and type information must appear, we can reach some conclusion about the stretch TTB is prepared to make. The information runs down the label as follows: From the Cellars of Lincoln Henderson Angel's Envy Finished Rye Rye Finished in Caribbean Rum Casks We know, because the database tells us so, that the two lines, "From the Cellars of Lincoln Henderson," is the fanciful name. We know, again because TTB tells us so, that "Angel's Envy" is the brand name. I do not know what TTB makes of the phrase "Finished Rye." So, by default, "Rye Finished in Caribbean Rum Casks" becomes the truthful and adequate statement of composition. Now, if you look at reviews by people who are suppose to know a thing or two about whiskey, they review Angel's Envy as whiskey, not a specialty. If the label says Bourbon aged in port, they review it as bourbon. No one is deceived about what they have and no one cares that TTB says it is a specialty, not whiskey. That may suggest some solutions to how gin "finished" in barrels can be marketed as gin without a claim that is offensive to TTB.
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