Variable Proof on Label, Handwritten?

[Sorghumrunner]

I'm wanting to do variable proof on my labels, and wanted to be able to handwrite the proof per batches, at least in our first bottlings. I swear that I have seen multiple labels with handwritten information, batch #, proof, bottler, etc. I submitted a question to TTB yesterday asking what I need to do to include this on my cola and was told that No Handwritten Information may appear on Labels.

Here is what appears to be a handwritten from one of the big boys:

https://www.blantonsbourbon.com/straight_from_the_barrel#

Should I just phrase this question differently? Anyone have experience with handwritten info on their label and the COLA process?

[Skaalvenn]

There have been some local distilleries which used to hand write their info but now print. I know some (not sure if all?) have switched to printed, but I figured it was due to the time it takes to hand write 1-2k bottles each month.

[rumfarmer]

I got exactly the same response from TTB. I submitted my reply asking again for the ability to hand write the proof. If it does not pass, I was thinking I would submit 10-15 different labels with proof statements within the range I expect for my cask strength product. Then, I will have stamps made for each that abide by the font size and style submitted. I would also like some advice, since I have seen others do this, too.

[TetonDistillery]

The percentage of alcohol in the bottle is how the taxes are calculated. So I suspect the TTB would reject anything related to variable proof labels.

Just my opinion. I have nothing to back that up with.

Most of the labels that I have seen with handwritten items are things like "Batch #34", "Distilled by (insert signature)", "bottled on September 30th, 2014".

Those are items that are not really of concern to the TTB, so nobody really makes a big deal out of it.

But the percentage of alcohol is an entirely different matter.

[Silk City Distillers]

"Cask strength" - Marketing term indicative of an overproof product, not necessarily the specific proof on a cask.

Estimate the lowest cask proof you expect.

Pick some funny decimal number near your cask strength estimate, I'd suggest ##.7 - since 7 is lucky. 59.7, 60.7, 58.7. Absolutely do not end in .4, very unlucky in Asian cultures. Bonus points for something clever like "Hard Eight Whiskey" 54.4 or "Snake Eyes Bourbon" 61.1.

Make minor proofing adjustments to each cask, or batch, to bring it to the specific product proof on your approved label.

From a consumer perspective, I would think a minor adjustment for federal reasons would be more than acceptable here.

Isn't this how everyone does it?

In the new America, where you can be sued for less, it seems much safer than selling a versions of a product with different label proofs, especially if they are being sold at the same price, someone is bound to scream bloody murder over being cheated .01.

[ebstauffer]

George T. Stagg has had hand written proof / abv details for as long as I can remember. My guess is that the lawyerly types at BT have their ducks in a row.

[Salishseaorganicliqueurs]

We are using variable proof on our labels. Variable proof works only if you stick to the proof range inherent to that class of alcohol. Here is the link to the TTB's variable proof exception. It should clear up 90% of the questions you have. When you submit your COLAs it has to have a proof or alcohol percentage written in and then you can later change it when it comes to producing your actual bottle. I talked with the head of the formulas and labels division at the TTB about it.

http://www.ttb.gov/labeling/allowable_revisions.shtml

[dhdunbar]

The commentators are correct. You can change the stated label proof if you follow the basic rules.

Change the mandatory statement of alcohol content, as long as the change is consistent with the labeled class and type designation, and all other labeling statements.

YES

YES

YES
(Flavored
Malt Beverages Only)

For example, you may change the alcohol content of a grape wine labeled with a varietal designation from 13 percent to 15 percent alcohol by volume, even though it results in a change to the product’s tax classification.

However, if the product was designated and labeled as a “table wine,” an alcohol content of 15 percent alcohol by volume would be inconsistent with the rules for use of that designation, so this change would not be permitted.

Similarly, a label bearing a “rum” designation may not be changed to state an alcohol content of less than 40 percent alcohol by volume. The revised alcohol content statement must be consistent with all other mandatory or optional labeling statements.

However. I know of no requirement that says labels must be printed. I think the regulations do not prohibit hand drawn labels. However, all mandatory information is subject to "type size" requirements found in 27 CFR 5.33. In fact, if you have not read that section, I recommend that you do so. There you will find, for example, the following:

(5) Statements required by this subpart, except brand names, shall be in script, type, or printing not smaller than 2 millimeters (or 8-point gothic until January 1, 1983), except that, in the case of labels on bottles of 200 milliliters or less capacity, such script, type, or printing shall not be smaller than 1 millimeter (or 6-point gothic until January 1, 1983).

(6) When net contents are stated either in metric measures or in both metric and U.S. fluid measures, statements required by the subpart, except brand names, shall be in script, type, or printing not smaller than 2 millimeters (or 8-point gothic until January 1, 1983), except that, in the case of labels on bottles of 200 milliliters or less capacity such script, type, or printing shall not be smaller than 1 millimeter (or 6-point gothic until January 1, 1983).

So, when a TTB specialist says you cannot have hand written statements on labels, ask them to explain the "script, type OR printing reference" in these sections of the regulation. That said, I do not advise that you take my word for this. Get TTB to commit in writing to any claim that you may or may not have handwritten entries on labels.

[dhdunbar]

Okay - my apologies for the way the above post appears. The table looked fine until I pushed the post button. To see it in better form, go to the TTB web site and look at changes you can make to labels without getting a new COLA.

[LibertyCall]

I asked the same question to a couple of distilleries near me, and the consensus was that you need to apply for the COLA with a label that has a Font that LOOKS like it's hand written at a specific proof/ABV. Then when you actually get the labels you can then hand write the exact proof on the label.

It's a work around, but I'm submitting my labels based on it. We'll see how it goes.

[Dehner Distillery]

Sounds like a lot of work to write on several thousand labels. Maybe you should just buy a stamp.