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So we have been trying unsuccessfully trying to get the TTB to respond to the question...."what do you (standards of identity) call a grain based product not aged in OAK barrels?"....apple barrels, cherry, etc., that of course calls the question what constitutes "aged in oak containers", a.k.a "the five second rule", what constitutes an "oak container" and what constitutes "new". (We got the TTB to allow us to use a modified, new, "traditional" oak barrel for use without attribution....easily, efficiently, happily, amazingly!!) I think we (micro-distillers) will eventually drive the TTB admins. to drink....imagine the huge increase in work load they are facing....like about a 4000% increase in bi-monthly revenue reports and the like (as our new, New York Governor says, "Jobs,Jobs,Jobs")....witness TTB-2011-0010-0001!!! (Comment period is soon to close, BTW) Let alone trying to define and adapt to the huge innovation and entrepreneurial force that WE, as micro-distillers represent. I have come to the opinion that WE (micro-distillers) are not competitors and that WE (micro-distillers) can easily take market share from the big boys via home turf relationships, neighbors and barkeeps and the like that adopt us as "local boys and girls make good" stories and brands. So the internet folks (IETF) have successfully out innovated the (read TTB regulatory and BIG alcohol) inertia and retained control of security, additional features, IM protocols and the like....maybe the ADI should be an self policing organization that defines new aspects of micro-distilling and interfaces with the TTB to help them/us through his watershed change....cause we are just now getting wheels under this bus.... The BIG alcohol folks are asleep at the wheel and yes though they have the cash to innovate, really can't, based on need to keep the monster brands producing results every 3 months. So has anyone got a product out there that has been sanctioned by the TTB via some "standard of identity" for grain spirits NOT aged in oak?
Looking for some insight and resolutions from anyone that has experienced the same situation... Currently working (more like forcing!) a whiskey COLA approval through. I teamed up with a local brewery to make the beer and I distilled it to produce a whiskey. To reflect this I stated "Distilled from full flavored craft beer" and TTB is not having it because the word "beer" shows up on a "distilled spirit" product. So they are requesting a formula approval. I explained that it is merely distilled from a beer mash just like any whiskey albeit a particular kind of beer mash (chocolate oatmeal stout beer mash and doppelbock beer mash). They want the formula approval (which I don't want to wait around for, of course) to decide whether it should be classified as a whiskey or a distilled spirit specialty product. Seems absurd since it is "Spirits distilled from a fermented mash of grain at less than 95% alcohol by volume, etc etc" just as defined by regulation. The mash of grain is called a distiller's beer so I'm not sure why they're looking at it as if I've done something ridiculous and added beer to a whiskey. Anyways, I see Corsair has their Oatmeal Stout Whiskey with a statement "Distilled from an Oatmeal Stout Distiller's Beer" so I'm going to try and reword it like that. It seems Great Lakes Distillery did something similar by teaming up with a brewery nearby using their pumpkin lager and they've got a statement of "Spirits distilled from grain and pumpkin with spices and natural flavors" which seems they had to go the distilled spirits specialty route. However, a distilled spirit specialty product is stated in the BAM as "Generally, any class and/or type of distilled spirits that contain or are treated with flavoring and/or coloring materials and/or nonstandard blending or treating materials or processes" which doesn't apply to a simple distiller's beer mash as I did none of the listed items. So, that is my rant. Curious how anyone else may have listed the Class/Type for a similar situation, if any. I imagine it'll eventually get approved as a whiskey since the formula will show 50%+ of the ingredients are malt and barley...so perhaps I should just suck it up and wait for the formula...but then again it always rubs me the wrong way on how self-righteous TTB can be... Thanks for any and all help, suggestions and comments!