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P.T. Wood

Barrel Aged Gin

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I just got my barrel aged gin COLA back marked "needs correction barrel aged statements on gin are misleading re:27 CFR 5.40" And yet I could find at least 5 gins marked "Barrel Aged" I am waiting for a specialist to call back but while waiting was wondering if anyone else had dealt with this problem?

Cheers,

P.T.

p.s the relevant section

27 CFR 5.40

(d) Other distilled spirits. Age, maturity, or similar statements or representations as to neutral spirits (except for grain spirits as stated in paragraph © of this section), gin, liqueurs, cordials, cocktails, highballs, bitters, flavored brandy, flavored gin, flavored rum, flavored vodka, flavored whisky, and specialties are misleading and are prohibited from being stated on any label.

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We talked about that with our consultant and he said that he can not believe that folks have received approval on labels where gin was listed as aged. We haven't dealt with this issue, yes. Keep us posted.

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It probably falls under the Distilled Spirits Specialty formula and COLA. If you want to make a spiced rum (DSS) or a spice flavored rum (FLAVORED RUM) you can do some seemingly odd labeling within the DSS but they wont just tell you that, you have to ask "How do I make my product say...?"

We don't have a barrel aged gin but thats my guess.

Kristian

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It seems to be the word "aged" that they have a problem with, which the CFR does clearly ban. Even after reading this stuff thoroughly I missed that important paragraph before submitting for my COLA.

I would add that although the CFR does say it is misleading I would argue that since it is in fact barrel aged it is the opposite of misleading.

IMG_20130211_190611-1.jpg

Seems like one more part of the CFR that needs to be revisited. But for now it is time to put on my creative pants and come up with something that says "Barrel Aged" without using "Aged"

Cheers,

P.T.

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...come up with something that says "Barrel Aged" without using "Aged"

• Cask Conditioned

• Matured in American White Oak Barrels

• No Spring Chicken as the result of prolonged exposure to Oak

Whatever you call it, I'm coming by today for a sample!

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P.T. Wood, simply put "Wood's Barrel Aged" on the line marked brand name on your COLA form, and you're all set.

Happy distilling!

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Thanks Guys! I'm going with the Spring Chicken line! I got a glass ready for ya Len!

Cheers,

P.T.

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So after a long discussion with the TTB we settled on "Barrel Rested" Not perfect but it will do...

IMAG0273.jpg

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So after a long discussion with the TTB we settled on "Barrel Rested" Not perfect but it will do...

Hey, I like the "barrel rested" designation, it harkens to "repasado" used for tequilas. We are thinking of just calling it the "barrel reserve" version of our gin.

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had opportunity try some of your Barrel aged Gin, fantastic stuff, but would have a very hard time categorizing it.

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Yes we had the same issue. Twice. We have a barreled aged almond liqueur. We tried "Barrel Aged" "Barrel Rested" and "Barrel Finished" all rejected. We ended up going with just "Barreled". For our gin we simply called it "Reserve" and left the barrel out of it. I am not surprised to hear that you got "rested" approved no more then other aged gins that actually have an age statement on it.

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Is "barrel aged" a problem because you use a neutral at the base of your gin? I ask this because in Holland we make genever. Dutch Gin. That's not made from a neutral, but from a maltwine (an unaged whiskey). Now, that can be barrel aged without problems, just as a whiskey can.

Odin.

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Is "barrel aged" a problem because you use a neutral at the base of your gin? I ask this because in Holland we make genever. Dutch Gin. That's not made from a neutral, but from a maltwine (an unaged whiskey). Now, that can be barrel aged without problems, just as a whiskey can.

Odin.

Have you had that approved by TTB for label saying it is barrel aged, though? I am really curious, because we are working on our label for our "Old Genever" based on malt wine. We have thought to offer it as barrel aged. I don't think the TTB cares if the base is GNS or whiskey. The issue is that there is specific CFR language that you will not make statements about aging of a spirit like gin as part of its formal description.

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... but since you are not making gin, but a genever, ageing is important! That's why they should comply. Or maybe not, because there is legislation on genever having to be made in the low countries, etc.

My point: GNS redistilled with herbs will not age so much as gain taste from the wood. A "whiskey" or "maltwine" based genever will. Just like a whiskey.

My own genever to be marketed will be aged in barrels and I do not foresee any problems with "our" TTB. But I guess that does not help you. Your problem is they see your drink as a Gin and gin is not barrel aged, right?

Edwin.

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My own genever to be marketed will be aged in barrels and I do not foresee any problems with "our" TTB. But I guess that does not help you. Your problem is they see your drink as a Gin and gin is not barrel aged, right?

Edwin.

Yes, precisely. In the USA, the TTB classifies genever as gin, probably redistilled gin unless it is the very old style of a single distillation on mash, then a distilled gin. Anything classified as a gin can not have an age statement as part of its required labeling (although I believe you are not prevented from explaining such processing in a detail description on a back label).

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Actually, the TTB classifies Bols genever as "Other Specialties & Proprietaries", a catch-all class for things they have no current legal definition for. It classifies Zuidam's oude genever and Corsair's genever as "other distilled gin". Zuidam's label states: "Single barrel - American oak".

Captive Spirits had this same problem with their Bourbon Barreled Big Gin. I pointed out that that an "age statement" is a specified period of time, i.e. defined by a number. "Barrel aged" is not a statement of age, it's a statement of treatment. "Twelve years old" is an age statement. If you're not giving a numerically-specified period, you're not making an age statement.

Still, 5:40(d) below makes it clear that "age, maturity, or similar statements" are not allowed on the specified products, ostensibly because that would ipso facto bemisleading. How they arrived at that erroneous conclusion is anyone's guess. Probably because no one foresaw the possibility that anyone would ever barrel age gin, liqueurs, or cocktails.

If a well-worded and supported petition for rule change were submitted, I have no doubt they'd drop that restriction, since it's self-evident that it's only misleading if it's not true.

§ 5:11 Meaning of Terms

Age. The period during which, after distillation and before bottling, distilled spirits have been stored in oak containers. “Age” for bourbon whisky, rye whisky, wheat whisky, malt whisky, or rye malt whisky, and straight whiskies other than straight corn whisky, means the period the whisky has been stored in charred new oak containers.

***

§ 5.40 Statements of age and percentage.

( b ) Statements of age for rum, brandy, and Tequila. Age may, but need not, be stated on labels of rums, brandies, and Tequila, except that an appropriate statement with respect to age shall appear on the brand label in case of brandy (other than immature brandies and fruit brandies which are not customarily stored in oak containers) not stored in oak containers for a period of at least 2 years. If age is stated, it shall be substantially as follows: “__ years old”; the blank to be filled in with the age of the youngest distilled spirits in the product.

( c ) Statement of storage for grain spirits. In case of grain spirits, the period of storage in oak containers may be stated in immediate conjunction with the required percentage statement; for example, “__% grain spirits stored __ years in oak containers.”

(d) Other distilled spirits. Age, maturity, or similar statements or representations as to neutral spirits (except for grain spirits as stated in paragraph © of this section), gin, liqueurs, cordials, cocktails, highballs, bitters, flavored brandy, flavored gin, flavored rum, flavored vodka, flavored whisky, and specialties are misleading and are prohibited from being stated on any label.

(e) Miscellaneous age representations. (1) Age may be understated but shall not be overstated.

(2) If any age, maturity, or similar representation is made relative to any distilled spirits (such representations for products enumerated in paragraph (d) of this section are prohibited), the age shall also be stated on all labels where such representation appears, and in a manner substantially as conspicuous as such representation: Provided. That the use of the word “old” or other word denoting age, as part of the brand name, shall not be deemed to be an age representation: And provided further, That the labels of whiskies and brandies (except immature brandies) not required to bear a statement of age, and rum and Tequila aged for not less than 4 years, may contain general inconspicuous age, maturity or similar representations without the label bearing an age statement.

(26 U.S.C. 7805 (68A Stat. 917, as amended); 27 U.S.C. 205 (49 Stat. 981, as amended))

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Is anyone aware of any official progress with this issue? It seemed curious to me that TTB didn't allow the use of 'Barrel Aged Gin', especially when there are plenty of products out there that use 'Barrel Aged Gin' as their product name (Dry Fly, Corsair, etc, etc)

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the TTB is all over the place on this. I believe the label approval depends on the experience of the person approving the labels. (looking at you Jefferson's Ocean Age and Absolute aged Vodka). Some spirits are not allowed to be classified as being aged while others require it. We need to petition the TTB to have more consistent label approval. Incidentally, has anyone been effected by the shutdown? Maybe it's like our local internet provider and they just needed to be powered down and powered up to work properly..

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I am stuck waiting on label approval for my Vodka !!!... And waiting , and waiting.... Hopefully this ends soon ....

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it's gonna have to. pretty soon they are going to run out of funds to pay themselves..

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