Gin from mash

[bluestar]

Glad to see these spirit topics up and running, and pleased to post in gin first!

I am curious about how many out there are producing a distilled (not redistilled) gin directly from mash or wash? If so, what kind of mash or wash are you using? Is it a traditional dry gin, or a genever?

Update: is there no-one making distilled gin without redistillation? (I know there must be...)

[Jonathan Forester]

there are several that I know of, but for the life of me I can't remember who. too much information, too few brain cells. W

[coop]

We at Colorado Gold make ours from a grain mash bill, strip the alcohol then re-distill using various botanicals. Coop

[bluestar]

Thanks, Coop. But you are still considered a redistilled gin according to BAM, rather than a distilled gin, correct? Because you distill from ferment, then add botanicals, and redistill. Just that you are doing that from either a low wine or a whiskey base, rather than a GNS, correct? If so, then you must be reporting a formulation. From what I learned from TTB, a formulation is not required for a distilled gin from ferment, but is required for a redistilled. Again, anyone out there distilling from ferment? I think it is also interesting to know from others like coop redistilling from a primary distillate that is not GNS if you must report your formulation as a redistilled gin.

BlueStar

[Quirk]

I know Breucklyn Gin is distilled from grain in house. I used to live down the street from them, and meeting Brad and learning his process was a huge inspiration for me.

[coop]

I don't know but I do not think that the way we make our gin would be considered from GNS. I think that if some one made their gin from the first striping run it would not be very good at all, too many other things coming through in the spirit. To be considered a GNS would mean it is distilled from a Neutral Spirit void of color, flavor, odors. Stripping runs are not void of anything??? Coop

[bluestar]

I don't know but I do not think that the way we make our gin would be considered from GNS. I think that if some one made their gin from the first striping run it would not be very good at all, too many other things coming through in the spirit. To be considered a GNS would mean it is distilled from a Neutral Spirit void of color, flavor, odors. Stripping runs are not void of anything??? Coop

Agreed, you are not from GNS, but you are I think redistilled. We are considering one such formulation, starting from a white whiskey base (all wheat), then adding botanicals and steeps, and then redistilling. If you have a still with enough separation, however, you could produce the gin directly from a mash or beer, just like you could produce a whiskey from it in a single run, but you would include the botanicals either in the beer or in the condensation path in a gin basket, usually before any dephlegmator or thumper, but could be before or after plates. This is closer to the method for making a genever, I believe, and will provide significant congeners from the base ferment. This is what I think the TTB is calling a distilled gin, and does not require you to provide a formulation to them. On the other hand, in your case you would be a redistilled gin, and would have to provide a formulation? It is this last point I am still curious about, because I have seen some posts indicating that they were told by the TTB they did not have to provide a formulation when producing gin the way you are.

If my interpretation (and that of the TTB agent who communicated it to me) is correct, it is odd, because it is unclear why a formulation would be required when distilling from a distillate and botanicals (redistilled) but not from a ferment or beer and botanicals (distilled).

Anyone out there producing from a distillate, but has been approved and treated as distilled (not redistilled) by the TTB (ie, did not have to submit formulation to obtain COLA)?

[coop]

A lot seams to appear here on this forum from lots of different people whom have talked to a TTB agent and they understood the conversation one way and some one else would take it an entirely different way. And I am sure if each and every one of us ask the same question to a different TTB agent we would no doubt get a different answer. We all need to understand that the laws and regulations, which we all do not understand, with maybe the exceptions of a few lawyers that chime in on us from time to time, were written many many years ago, I think around 1903 if not sooner. The persons that wrote those regulations are I am very sure not around any more to tell us just exactly what they really meant, and just like our fore fathers who wrote the Constitution and Bill of Rights. We have no possible way to really know just what they intended for each and every word they wrote down. I am sure that each and every TTB agent we talk to is trying their very best to give us clear answers to all our questions as best they can. There is so much that is left for interpretation like our tax laws, That we will never really know just exactly what they mean. So we all must do the best we can, and if we make a mistake, it is just that a mistake, because I am sure none of us are intentionally trying to break a law. One should never feel bad because he or she may do something wrong, that is how we learn. Just rambling along, doing the best I can and having one hell of a good time. Coop

[Ned]

I'm coming a little late to the discussion but have recently given this a lot of thought as I prepared to send my labels in for approval. The way I interpret the BAM as it pertains to gin is that they are interested in the base material as it entered your plant. In the case of distilled gin, you start with a mash and may distill it a couple of times before adding botanicals, but you start with a mash; grain or fruit or sugar entered your plant to become that mash. In the case of redistilled gin you are starting with GNS as your raw material, a container of GNS entered your plant. The fact that you run a stripping run and then run the low wines back through the still are simply part of the process from mash to gin, the same as if you run a whiskey through your still 2-3 times you're not making redistilled whiskey. That's my interpretation, and as Coop pointed out, it's the best I can do.

[bluestar]

Seems reasonable, although I don't think it has to be GNS, it could be some other base spirit you bring in. But if you are correct, the difference may reflect the TTB's license differentiation: if you a start with ferment, you are a distiller of the gin, but if you start with someone else's base spirit, you are a rectifier!

[bluestar]

I thought I would share the most recent (clear) statement I received from someone in spirits formulation at TTB:

My question: "But my understanding is that it is common practice to first distill mash to low wines before adding the botanicals, and then to distill this mixture of low wines and botanicals to produce gin. If the mash distillation and low wine distillation are both conducted in our distillery, would this still be a Distilled Gin and would this still not require a formulation review before COLA?"

The answer: "If the gin is produced as described, it would be considered a redistilled gin since it the botanicals are added to spirits and not to the mash. As such, it would require formula approval."

Just another data point, YMMV.

[bluestar]

Another data point from the TTB:

"The regulations do not address the issue as to when the botanicals are added, but rather how many times the product is distilled."

In other words, if the mash is distilled once, it is distilled gin. If the mash is distilled more than once, it is redistilled gin. I did get clarification that adding tails to mash does not change anything. Which means there could be a fairly absurd result: you could add a large amount of tails from a large mash run to a small amount of mash, and distill it, and it would not be redistilled.

I have the suspicion that somehow, over the years, the meaning of these categories has become confused. I suspect that the original idea was to separate those who were doing rectification (compounding or redistilling, starting with someone else's spirits) from original distillation (regardless how many times it ran through the still). That would explain why a formulation is required for the first two, but not for the latter. And why would running three time through a pot still be treated differently from someone running through a continuous still?

[Edwin]

Gin or genever are seldomly distilled directly from the mash. The heads and tails cuts would take away many of the berries & herbs tastes as well. Usually GNS is made or a maltwine is created thru 2 or 3 distillations. The herbs and berries distillation comes after that.

Edwin.

[bluestar]

Yup, which again begs the question, what was the "distilled gin" type created for in distinction to the "redistilled gin" type? And why does the former not require formulation, but the latter does? Because under these strict definitions, almost no one produces a "distilled gin" (although we do).

[Tom's Foolery]

The way I read it, the CFR allows for 3 types of gin, two of which require formulas because they are the result of changing a distilled spirit from one class/type to different class/type, and one which does not (from an original distillation of mash) because the gin was never a different class/type before becoming gin, even if botanicals are added after a first distillation (like a stripping run) but before a second distillation (like a finishing run)

Check out:

§ 5.27 Formulas. Formulas are required for distilled spirits operations which change the character, composition, class or type of spirits as follows:

(j)(1) Redistillation over juniper berries and other natural aromatics, or the extracted oils of such, of spirits distilled at or above 190 degrees of proof, free from impurities, including spirits of such a nature recovered by redistillation of imperfect gin spirits; and

(k) The treatment of gin by— (1) Addition or abstraction of any substance or material other than pure water after redistillation in a manner that would change its class and type designation;

So, if you are starting with Neutral Spirits (which is a class defined in the CFR), and redistilling it, you are making redistilled gin. If you are starting with Neutral Spirits and mixing it with botanicals, they you are making compounded gin. If you are starting with grain, and adding botanicals at any point before creating a distilled spirit that fits within a defined class/type, then you are making distilled gin and you don’t need a formula.

But to confuse things, The CFR further states:

§ 5.22 © Class 3; gin: Gin produced exclusively by original distillation or by redistillation may be further designated as “distilled”. “Dry gin” (London dry gin), “Geneva gin” (Hollands gin), and “Old Tom gin” (Tom gin) are types of gin known under such designations.

So, you can label redistilled gin as “distilled,” but it needs a formula. You cannot label a compounded gin as “distilled.”

But, I am not a lawyer …

[Edwin]

I am sorry, the differences (legally) between distilled and re-distilled ... don't make sense to me. I look at gin/young style geneva like this: a neutral that is either redistilled with herbs in the boiler, herbs in the column or with herbs taken out after maceration. The first one giving strongest taste notes, then the third one, and with the vapour infused gin being the lightest in general. "Genveva" or Hollands/Dutch gin is different as to that it isn't distilled from a neutral but from a "whiskey". Infusion: distill herbs (neutral or whiskey) and add that to a base neutral or base "whiskey" (maltwine to be precise). "Dry gin" is a type of gin redistilled at higher abv thus giving a very dry taste/flavor.

Edwin.

[bluestar]

Edwin, all of the latter are redistilled, and hence require formulation. The only one that does not require formulation is if you distill only once from a fermented source. I have confirmed that with different TTB officers. I never understood what the reasoning could be, but I think maybe Tom's Foolery hit upon it: a formulation is required if you are going to start from another spirit to describe the spirit it comes from. So if you distill twice in your own distillery, at some intermediate point the spirit is another classification, as Tom Foolery suggests, and formulation is required. But, following that logic, as long as I keep throwing some juniper in, I could theoretically keep redistilling, and each step is a gin, so could I skirt formulation? LOL

[Palmetto Coast]

Just a thought... Couldn't you strip with a gin basket of juniper (or a handful, for that matter), then do the finishing run and include any types of botanicals you want? This would take some recipe development, but since the juniper was in the original distillation, it is gin, and would not require submitting formula approval.

Todd

[Edwin]

If that is the way we should interpret it, it does not make sense. Ned's explanation would. Who the heck is making a gin from a wash directly? That's ridiculous. Cuts you need to make on the crude mash will ruin fruit components coming over. Tails cut would ruin roots contribution to the gin. Low abv will hamper enough tasty oils travelling over. Low abv of a wash will not extract enough taste in the first place.

Maybe the way described is how the TTB interprets it now, but it cannot be meant that way.

[tl5612]

Who the heck is making a gin from a wash directly?

http://www.masterofmalt.com/gin/breuckelen/breuckelen-glorious-gin/

[bluestar]

If that is the way we should interpret it, it does not make sense. Ned's explanation would. Who the heck is making a gin from a wash directly? That's ridiculous. Cuts you need to make on the crude mash will ruin fruit components coming over. Tails cut would ruin roots contribution to the gin. Low abv will hamper enough tasty oils travelling over. Low abv of a wash will not extract enough taste in the first place.

Maybe the way described is how the TTB interprets it now, but it cannot be meant that way.

It is how it is interpreted now.

It is how we make it now, with botanicals both in mash and in head.

But we are using a 4 plate still, so we get 170 proof. Yes, we have a tighter relationship between cuts for grain and cuts for botanicals.

Any redistillation, regardless when the botanicals are added, according to TTB requires formulation.

I have also puzzled over what was originally meant by a distilled gin when created. We can speculate, but the TTB won't say and there is no documentation.

[bluestar]

http://www.masterofm...n-glorious-gin/

nope. from their website:

Glorious Gin

Our original gin recipe. Distilled from wheat grown in upstate New York. We redistill our base spirit in the presence of juniper, lemon, rosemary, ginger, and grapefruit.

[bluestar]

Just a thought... Couldn't you strip with a gin basket of juniper (or a handful, for that matter), then do the finishing run and include any types of botanicals you want? This would take some recipe development, but since the juniper was in the original distillation, it is gin, and would not require submitting formula approval.

Todd

nope. more than one distillation, whenever the botanicals are added, make it a redistilled gin, and requires formulation, according to the TTB.

[Edwin]

I understand you want to make a gin from a wash and not from GNS. That's what genever is all about for example. But the wash is always distilled first. Cuts are always taken on the low wines. And then it is the "gin" run. If Breuckelen (Dutch city giving the name to Brooklyn, by the way) does that, I completely understand. It will give them a more interesting product. But if I look at how some (TTB included) interpret a distilled gin, it would mean that Breuckelen (by that definition) makes a wash of - say - 8% and distills that with botanicals in the boiler or vapour path. In my experience that method (if that is the method they use) will not work. ABV in the boiler is too low for good herbs flavor extraction. And if the herbs are somewhere on top of a multiplated column, ABV will be right, but you will still need to make cuts for heads and tails. In cutting for heads and tails, you will get rid of some of the most interesting herbal notes ... Sorry if I turn this tread into a "how to make a great gin/genever" instead of "how to interpret TTB regulations". I am no expert on TTB regulations, so maybe I should not post here.

[tl5612]

nope. from their website:

Glorious Gin

Our original gin recipe. Distilled from wheat grown in upstate New York. We redistill our base spirit in the presence of juniper, lemon, rosemary, ginger, and grapefruit.

Whoops. Don't know why I thought it was just one run.

Apologies to Breuckelen.