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Gin from mash

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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.

I agree, everything you say is true, including the challenge or limitation of what happens with the botanicals in the still head. But it is what we have done. It makes for a product that tastes very much like a gin-flavored whiskey. I wish you could taste our product, because I think it is very interesting, but it is not a redistilled gin, whether of the dry type (from GNS) or from low wines. Our first genever is made the same way, on a barley mash (we actually use grain-in mash instead of wash, about 10% ABV). Nevertheless, we do get a very juniper forward product.

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One TTB agent told me the gin rules had root in what type of extractives were obtained from different strength washes.

If I got the explanation straight, adding certain botanicals to a low wine or ngs can lead to potentially toxic concentrations of certain compounds. By requiring formulas, the TTB can regulate what exactly in going into your gin. However, distilling from a primary wash is considered "safer," (by whom, I have no idea...they may not have had a very good grasp of what goes on in a still) and less able to extract toxic quantities of questionable botanicals. Hence, the "no formula."

It's the most coherent explanation I've had so far. But it still seems pretty arbitrary to me.

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Just to throw in my two cents. I've never come across a gin where the botanicals are added to the wash. There are some gins that just macerate botanicals but then they all use NGS.

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Here's an example of a clearly labeled 'Distilled Gin' where the botanicals are not added until final distillation. It would seem no formula approval is needed then, right?:

http://greenhatgin.com/#process

"In the final distillation, we suspend our hand-selected botanicals inside the still to allow passing spirit vapors to gently extract the right flavor and scent notes."

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Here's an example of a clearly labeled 'Distilled Gin' where the botanicals are not added until final distillation. It would seem no formula approval is needed then, right?:

http://greenhatgin.com/#process

"In the final distillation, we suspend our hand-selected botanicals inside the still to allow passing spirit vapors to gently extract the right flavor and scent notes."

According to the TTB, that is a redistilled gin (which are labeled "Distilled Gin" according to BAM, both distilled and redistilled are labeled that way). So, yes, it requires formulation.

Rule is: if the spirit in the gin is distilled more than once from original ferment to get to the final product, you need a formulation.

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Certainly understand what you're saying and see the distinction between the two in the BAM, I guess I'm just still confused about where the BAM enables them to label a redistilled gin as a 'Distilled Gin'. Are you basically saying that the product designation on the label is not representative of the distinct BAM designation (distilled vs. redistilled), and therefore not representative of the formula approval requirements? In other words, TTB allows a redistilled gin to be labeled as 'distilled'?

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Keep in mind that the BAM is just a guide book the TTB put together ...The BINDING document is CFR 27 .....

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