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Fruit in Gin Basket for Flavored Vodka - Class Designation?

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Say for example I wanted to make a flavored vodka using the same process I use for my gin.  I would start with my vodka that was distilled >95%, dilute down to 30%, and run it through my basket.  Since this will then come off the still less than 95%, is this still considered vodka?  Since it originally started as vodka, does redistilling it <95% affect its class, or would it still fall under a Flavored Vodka?

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Technically, I believe it would become a 'spirit' at that point.

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In a flavored spirit, you have two or more ingredients.  The first is the spirit component (vodka, whiskey, brandy, gin, rum).  The second (and third and fourth, etc) are the aromatics and botanical you put into the gin basket.  

If you produce a neutral spirit, 190 or more proof, and designate it neutral spirit when you make the production gauge (see 19.304 and 19.305), then it is not vodka unless you do something more to "purify" it in the processing account (see 5.22(a)(1) - "(1) “Vodka” is neutral spirits so distilled, or so treated after distillation with charcoal or other materials, as to be without distinctive character, aroma, taste, or color.

The something more could be filtration (under the general use formula) or it could be redistillation (Tito style, I believe). 

However, if you  declare it vodka at the time you make the production gauge, then it is vodka and you do not need to do anything more to it in the processing account. 

Those distinctions are a silly naming game for which I have no explanation.     But it is what the regulations say.

Flavored vodka is vodka to o which has been added natural flavoring materials, with or without the addition of sugar, and bottled at not less than 60° proof. The name of the predominant flavor shall appear as a part of the designation (5.22(i)).

Obviously, I say "obviously" with a smile, since you can label 80 proof spirits as vodka, the spirits that you redistill in the processing account do not have to be 190 or more when you redistill them.  Musty they be 80 proof?  Logic seems to say so.  But what will 
TTB say?

So, I think that they need to have been 190 or more when you completed the original distillation and,  by reasson of logic, to meet the vodka standard, they may need to be 80 or more proof when you redistill them. 

To be clear, I'm arguing, from the regularization, that since 60 proof neutral spirit is not vodka,  vodka does not go into the redisaitllation, so what comes out cannot be flavored vodka.  

If TTB holds to such rigorous standards, what comes out of the redistillation would;d be a specialty item, which you would label under 5.35 with a fanciful name and truthful and adequate statement of composition, i.e., neutral spirits with natural peach flavor, or maybe peach flavored neutral spirits, but not peach vodka.  .

The same is true, by the way, if you flavor neutral spirits that have not been declared vodka.  

In my opinion, this is all silly games.  No consumer is being mislead in any way if you call the product peach flavored vodka.  

I suspect that when you submit your formula to TTB, TTB will not object on the grounds I've stated above.  I've only followed the syllogistic logic to the conclusion that follows from an "if A then B" sort of rigor that yields worst case scenarios.

So, I would submit a formula for TTB's approval, which includes a statement of process that shows that (1)  you distill spirits to 190 or over, (2) cut the neutral spirits to 60 proof, (3) re-distill them over aromatics and/or botanical in a gin  basket,  (4) collect the flavored distillate,  (5)  bottle the flavored distillate  at 60 proof or more, and (5) call it flavored vodka.  Then I'd wait to see what TTB says.  I think the designation Peach Vodka will fly.  

 

 

 

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I think what @dhdunbar said is correct, but I found it a bit hard to follow, so I will summarize what I thought was the most important takeaway: you might not be able redistill the product with flavoring components and call it flavored vodka. It might be a specialty. Flavored vodka is vodka that later has flavorings and maybe sugar added to it. And a formula will be required. If your formula says you are redistilling (and you must say so if you are doing so), I think they will tell you it is not flavored vodka but a specialty. I can see the argument against this if you take vodka and then redistill with a gin basket: the product entering the basket is still vodka, and that you flavor it by high-temperature vapor infusion should mean it is flavored vodka. Not an unreasonable argument, try it out in your formula submission as @dhdunbar suggests. I think where you could run into a problem with the process you describe is that you are diluting to 30% before redistillation. Now the product is not vodka (has to be above 40%), although again since 60 proof is the minimum for a flavored product, maybe you can argue that, again as @dhdunbar suggests. And please relay the response from TTB, I am very interested.

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I'll try to distill what I tried to say without giving the reasoning behind it, quoting the regulations, or giving citations. 

You gotta start with vodka

If you are going to make flavored vodka, you need to start with vodka, then add flavor to the existing vodka.  If you start with something other than vodka as the base spirit, the final product cannot be flavored vodka.

You can make vodka two ways

You can make vodka by calling  any neutral spirit vodka when you produce it.  But if you don't call it vodka when you , it is not vodka.  It is only neutral spirits. 

That is a weird provision.  If a spirit is distilled at 190 or more, then it is either neutral spirits or it is vodka, depending only on call it when you transfer it from the production account into either the storage or processing account.

So. if you first say it is neutral spirits, then you must do something more to change the designation from netural spirits (a class of spirits defined to be colorless, odorless and tasteless) to vodka (a type within the class that is somehow more colorless, doerless, and tasteless that something that already is colorless, odorless, or tasteless).  That defies logic, but that is what the regulations say.

To manufacture vodka from neutral spirits,, the something you can do is filter or redistill or otherwise treat the neutral spirits to make them more neutral. 

That is a game.  But it is a game you must play to get vodka out of something you first said was neutral spirits.  i

That is the first part of the discussion.

You start with vodka, what then?

So, assume you have vodka, however you came to acquire it. 

If, before you redistill the vodka over the flavoring,  you dilute  the vodka to less than 40 abv, it is no longer vodka.  It is diluted vodka ( here is a reference for that, because I did not cite it before - ATF Ruling 75-32). It is diluted vodka because it has too little alcohol by volume to be vodka. 

But oops, if you add flavor to diluted vodka (how you do that does not matter), you are not adding it to vodka, because diluted vodka and vodka are two different products.

Therefore the product doesn't qualify as flavored vodka.

Since it conforms to no standard of identity, it is a specialty.

Wonky nonsense

This is all  wonky nonsense.  What does it matter to the character of the product that ends up in the bottle?  Nothing! 

Taking a product you could have called vodka, but called neutral spirits instead, then cutting that product to 30% abv instead of 40@prior to redistillation using vapor extraction to create a flavored product that you bottle at 30% abv or more as flavored vodka is not misleading to the consumer.

So submit the formula and see what TTB says.  

 

 

 

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