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Lorenzo

Why would Gin require a formula

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Hi All,

Recently submitted an application For COLA approval, for our Gin, on the first go we were told to make corrections , a  commodity statement was needed, so on the back label we inserted 100% neutral spirits distilled from grain, we were rejected and told by the reviewer that we will need an approved formula !  I’m confused we are using our own Vodka,  and botanicals by vapor infusion. I’m not embarrassed to say that I’m new to distilling, but someone correct me I can find nothing online on the requirement for a formula for botanical Gin. What should appear on the label for a commodity statement.? Maybe “distilled from grain” 

Thanks.  Lorenzo

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I believe "Distilled from Grain" would be sufficient.

And, if you distilled your botanical in the pot, no formula is needed. Vapor and maceration require a formula.

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If anything you use is not on the FDA's GRAS list you'll need to submit samples.

https://www.fda.gov/food/food-ingredients-packaging/generally-recognized-safe-gras

Also a good list: https://www.cocktailsafe.org/

 

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From a formula perspective, the TTB categorizes three gin processes: distilled, redistilled, and compounded.  The only one that doesn't require a formula would be distilled gin.  You can look up formula requirements for all classes and types on this table:

https://www.ttb.gov/images/industry_circulars/archives/2007/pre-cola_eval_spirits.pdf

Whether your gin is classified as "distilled" or "redistilled", if you make multiple passes through your still, has been debated on the forums before.  The definition below would indicate that if you perform the original distillation, regardless of how many passes through the still, you are producing a distilled gin and don't need a formula.  Obviously, you'd still have to stick to the GRAS list.

ATF PROC. 86-3 (doesn't look like it's been superseded)

Distilled Gins

Section 5.22(c), Class 3, defines "gin" as a product obtained by original and continuous distillation from mash, or by redistillation of distilled spirits, or by mixing neutral spirits, with or over juniper berries and other aromatics, or with or over extracts derived from infusions, percolations, or maceration of such materials, and includes mixtures of gin and neutral spirits. It shall derive its main characteristic flavor from juniper berries and be bottled at not less than 80 proof. Gin produced exclusively by the original distillation or by redistillation may be further designated as "distilled."

If you think you meet that definition and are producing a distilled gin then you'd need to resubmit your label and list class/type as "distilled gin".

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Whether you macerate, use a gin basket, or vapor expose, does not determine if you are distilled or redistilled. For sure, with any of these methods, if you are distilling directly from ferment, you are a "distilled gin" and do not need a formula. Moreover, if you distill from any spirit previously classified as ANY specific spirit other than gin (purchased, stored, transferred, etc.), you made a "redistilled gin" and require a formula. Okay, here is where it gets tricky, and where I have obtained conflicting guidance from different people at the TTB. If you are distilling a product in production, and it stays in production for additional distillation (never moved to the storage or processing account), with the final distillation producing the finished gin, and maintain in the intermediate gauging and records that the product is gin "in production", then it could be considered "distilled gin" and not require a formula. Just like if you distill something 5 times to make vodka with only the last distillation being over 190 proof, or 3 times to make whiskey. In this interpretation, it is the change of classification of the spirit from a non-gin class to gin that makes the formula a requirement, as it would if I had product that was classified as whiskey, then redistilled to make vodka, and thus would normally require a formula. However, two countervailing points: 1) we have submitted formulas for vodka where we redistill essentially unaged whiskey or feints, prior to its finish, and have been told that a formula is not needed (or submitted formula was not approved with the comment that it was not needed); and 2) we have had one TTB officer in Formulation tell us a formula is required for gin as a "redistilled gin" so long as more than one distillation is performed. It would really help if the TTB would write a guidance note on this specific issue. It is all about how one defines "original distillation", since it does not call out "single distillation".

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Thanks everyone, all of you were very helpful, Bluestar you you nailed it, the person I spoke with at TTB essentially  same the same thing if it stays in production , but questioned my process to make the GIN, my product will state distilled from grain, (if they approve it  !! 😁)      Lorenzo

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COLA personnel have no idea if you do or do not put your product into a processing account. There are no line items on a COLA app for that. Actually Formula personal don't really care that much either. So I don't thinks that's the issue.  

I beleive the COLA examiner was confused by the term "100% Neutral Spirits Distilled from Grain".  I've read that 5 times and still don't know what it means.  Is this NGS from your friendly neighborhood pretend craft mega producer, or are you distilling this in-house from grain ?

if it's mega-craft then it is essentially redistilled and needs a formula, if you are making your base from scratch, then I beleive it does not require a formula, but will require you to state: distilled from grain (or wheat, corn, etc..) at your discretion. 

Prost 

 

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13 hours ago, Roger said:

COLA personnel have no idea if you do or do not put your product into a processing account. There are no line items on a COLA app for that. Actually Formula personal don't really care that much either. So I don't thinks that's the issue.  

I beleive the COLA examiner was confused by the term "100% Neutral Spirits Distilled from Grain".  I've read that 5 times and still don't know what it means.  Is this NGS from your friendly neighborhood pretend craft mega producer, or are you distilling this in-house from grain ?

if it's mega-craft then it is essentially redistilled and needs a formula, if you are making your base from scratch, then I beleive it does not require a formula, but will require you to state: distilled from grain (or wheat, corn, etc..) at your discretion. 

Prost 

 

Sorry, is doesn't matter what the COLA people know, you are responsible to make sure you meet the requirements for a label for a spirit that does NOT require a formula. For example, the COLA people don't know if you age your whiskey for more than 4 years, but if you submit a label with no age statement for the whiskey, it will be approved, even though there is no place for you to indicate on the COLA that you aged less than 4 years. They ASSUME you will have done so, and won't know unless they audit you. The SAME is true for gin, whatever the rules actually are. If you make a compound gin and bottle it and label it with a label that says it is a distilled gin, they don't know, UNLESS you submit a formula that says so, and tie it to the COLA. But I do agree, that a statement on the label saying "100% Neutral Spirits Distilled from Grain" suggests at some time the spirit was classified as neutral spirit, in which case, making it into gin would be a change in classification, and would require a formula.

By the way, it was the TTB that let me know that moving something into storage or processing NOT as one spirit (in this case NOT gin), and then later processing or further production so that it CHANGES classification (in this case, into gin) will trip the requirement for a need for a formula. OF COURSE they won't see that when they approve your COLA. It will only become apparent if someone audits you, sees your paperwork changed the classification, checks the bottles of product to determine what label was on it, and ties it to the production records. So sure, they will probably never catch you.

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I also am running into this situation with label approval with my gin. My application has been returned back to me for correction three times now. Third time is a charm, I hope. TTB has required a formula for which I have received approval, and now they ask for a change in classification from "Distilled from _________." to "100% Neutral Spirit Distilled from__________." There seems to be a lack of continuity depending on which ttb specialist is assigned to your label and or formula.

Having my label state "100% neutral..............." I feel will hurt my retail sales as I am distilling from Whey. All done in house from original distillation. I do not put it into storage or change from neutral .

My question is this. Once I receive label approval with their requested corrections, may I apply for another Gin label that will more accurately reflect the message I hope to convey without drawing to much attention to my application?

Should I state these pionts on a new application under Notes to Specialist? 

Thanks

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2 hours ago, brokenarrow1560 said:

I also am running into this situation with label approval with my gin. My application has been returned back to me for correction three times now. Third time is a charm, I hope. TTB has required a formula for which I have received approval, and now they ask for a change in classification from "Distilled from _________." to "100% Neutral Spirit Distilled from__________." There seems to be a lack of continuity depending on which ttb specialist is assigned to your label and or formula.

Having my label state "100% neutral..............." I feel will hurt my retail sales as I am distilling from Whey. All done in house from original distillation. I do not put it into storage or change from neutral .

My question is this. Once I receive label approval with their requested corrections, may I apply for another Gin label that will more accurately reflect the message I hope to convey without drawing to much attention to my application?

Should I state these pionts on a new application under Notes to Specialist? 

Thanks

Are you in fact producing 100% Neutral Spirits Distilled from Whey, and then using that to make a "London Dry"? IE, a redistilled gin made from 100% neutral spirits? In other words, are you distilling the whey ferment to higher than 95% ethanol?

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The ferment in fact does distill at over 190 degrees proof, however it stays in production without moving to storage or processing as per your earlier post.

Final distillation produces the finished gin.

Thanks again for the assistance

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My label application has been sent back for correction again, as the type face and font is not the same size. "100% neutral..........." Blah, Blah, Blah...

Quite the learning experience, this.

I may withdraw the application and formula and begin the process from the beginning.

Any HELP or ADVICE would be most helpful. 

Thanks.

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