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27 CRF 5.22(G)(4)


sailorman9

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I want to produce a Flavored Rum at 45 proof. This spirit has more than 2.5% sugar and natural flavoring. I have been back and forth through the regs and I can't understand how Bacardi makes a Coconut Flavored Rum that is 42 proof. I want to call my spirit Flavored Rum, but it's not 60 proof. Am I missing something?

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Have you talked to the TTB about your formula? I can't offer specific formula experience other than pushing through a COLA for a new product in the past week, they (The TTB agent) required that i call the formula department and explain exactly how i was getting to the final product, which resulted in a "you don't need a formula, tell them Agent John Smith said so"... it worked, and the COLA was approved.

good luck,

-Scott

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Are you referring to Bacardi Coco Flavored Rum. If so, I'm pretty sure it's 70 proof. Also, did you mean 27 CRF 5.22(h)(4) for rum liqueur? I've not had any experience with this particular regulation, but a reading of the reg would imply that as long as you left out the word rum you could lower the proof to below 60 proof. 27 CRF 5.22(h)(4) further defines 27 CRF 5.22(h) when the designation "rum liqueur" is used. Probably the assumption by the TTB is that anything less than 60 proof is not to be defined as rum so rum can't be used in the name. Contact your local TTB officer and tell him/her what you are trying to do. They can be a good resource. I'd also suggest using a formulation attorney like Lehrman Beverage law. They can often find ways around and through the regulations to get your label approved the way you want.

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  • 5 months later...

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