Estimating Final Age Statement

[Patio29Dadio]

This might be a stupid question, but had the COLA and labels done for a bourbon and a rye including age statements based on assumptions for amount of time it would take to get to full extraction and maturity.   But for some of the barrels, the extraction is moving a bit faster than expected.  I assume I know the answer to the question about what to do with the label and COLA for the product... get new ones.  My question is more about how to others deal with this?  If you are waiting on a batch and you have one barrel that is a risk of going over-oaked, and you dump it early... then it becomes the basis for the age statement given that it is the youngest that would go into the multi-barrel batch dump.  So to stay in the line for the age statement you would need to amend your COLA and labels or else remove the barrel from the batch... which is not something always in the cards unless there are other products it could be used for.  Also, it seems not an effective business practice to wait until the barrels are ready to dump and then go get the COLA and labels.

Maybe this is the reason to make only straight whiskeys so there is no age statement required.  However, with younger whiskeys and those that are not classified as straight and less than four years old, it seems a problem to have a pre-printed label and per-COLAed product.    Am I missing something?

[Silk City Distillers]

We have resubmitted numerous labels for the same product as we’ve string age out longer.  We try not to overbuy labels.  1 year, 2 year straight.  Most of our age statements read “Aged at least xx years” now.  Our 2 year product contains barrels almost 3 years old.  In a few months we will reprint 3 and 4 year age statement variations.  I know more than once we dumped a barrel to run out label stock.

 

 

[bluestar]

12 hours ago, Silk City Distillers said:

We have resubmitted numerous labels for the same product as we’ve string age out longer.  We try not to overbuy labels.  1 year, 2 year straight.  Most of our age statements read “Aged at least xx years” now.  Our 2 year product contains barrels almost 3 years old.  In a few months we will reprint 3 and 4 year age statement variations.  I know more than once we dumped a barrel to run out label stock.

We are often in the same situation, considering we intentionally make some of our products available a 2, 3, 4 yo. Have you considered having the specific age not printed and adding that info onto the label at bottling, either by hand, or an overprinting?

[Jedd Haas]

You can change the age statement without filing for a new COLA. See number 14 on the list at this link.

https://www.ttb.gov/labeling/allowable-revisions

 

[Patio29Dadio]

Quote

You can change the age statement without filing for a new COLA. See number 14 on the list at this link.

Now that is interesting... I did not know.

The problem I have with reprints of labels and printing smaller batches is that the cost per label goes WAY up.  For my regular-size run they may be $.20 each, but for a small run they might be $.70 each.  I wonder if an age-range statement will work?   Aged ____ TO _____ ?

[Silk City Distillers]

That's why we moved to the "Aged At Least XX Years/Months" phrasing.

I do not believe your phrasing would be approved, or if it's approved, you need to ensure that every bottle contains aged spirit that coincides with BOTH the lower and upper limit, otherwise the upper limit is a misrepresentation.  Consumer might believe that the bottle contains a blend of whiskies older than it does.  Keep in mind that the age statement can be an understatement, but can never be an overstatement - if that makes sense.

 

[bluestar]

On 1/10/2020 at 7:56 PM, Patio29Dadio said:

Maybe this is the reason to make only straight whiskeys so there is no age statement required.  However, with younger whiskeys and those that are not classified as straight and less than four years old, it seems a problem to have a pre-printed label and per-COLAed product.    Am I missing something?

Straight whiskies need the same age statement as non-straights. It is just that a straight whiskey must be at least two years old (among other things). Only whiskies over four years old do not require an age statement. A straight whiskey between two and four years old requires an age statement.

[bluestar]

9 hours ago, Patio29Dadio said:

I wonder if an age-range statement will work?   Aged ____ TO _____ ?

No.

You still have not indicated why you could not write in the age on the labels, especially if you are doing such small bottlings? As @Jedd Haas pointed out, the actual age in the age statement is one of the items that can be changed on a label without having to resubmit for COLA approval. If you have not already done so, please go to the TTB website to download and read their guidance on changes to labels that don't require approval.

[Patio29Dadio]

On 1/12/2020 at 6:40 AM, bluestar said:

Straight whiskies need the same age statement as non-straights. It is just that a straight whiskey must be at least two years old (among other things). Only whiskies over four years old do not require an age statement. A straight whiskey between two and four years old requires an age statement.

Yes, I forgot the 2-4 years age statement requirement for straight whiskeys. 

 

On 1/12/2020 at 6:43 AM, bluestar said:

No.

You still have not indicated why you could not write in the age on the labels, especially if you are doing such small bottlings? As @Jedd Haas pointed out, the actual age in the age statement is one of the items that can be changed on a label without having to resubmit for COLA approval. If you have not already done so, please go to the TTB website to download and read their guidance on changes to labels that don't require approval.

I think that is what we will do.  A small sticker for now that covers the existing age statement.