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Barrel Aged Gin

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We are currently aging some gin.  I've seen through many topics here that the TTB is not allowing "Barrel Aged" on a gin bottle.  Is that still the case?  Are there any recent experiences that I can use to guide our choices for what to label it?  Must this be formulated as a Distilled Spirit Specialty?

I'm seeing many barrel aged and age stated gins on the shelves...

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What the CFR actually says is that no statement of age can be made for a gin. So generally, the wording "Barrel Aged" is rejected, since one could construe that as a statement of age (although I personally disagree, since no period is listed). The ambiguity here may be why some have rarely gotten a label approved with that phrase. For sure you can not state an age, like "aged six months", even on rear, like "we aged our gin for a year in used barrels". But you can say other things, again at the discretion of the TTB reviewer, like "Barrel Reserve", or "Barreled". But sometimes they can be fickle. We had them approve for one gin the phrase on the rear in body copy "this barrel reserve is set aside in used bourbon barrels before bottling" but not allow that phrase on a similar product. Go figure. Roll the dice. I think this is one of those areas where the industry should consider lobbying to modify the law, and allow age statements similar to rum.

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I've seen many bottles that explicitly say "barrel aged" and an age statement of "aged for x months."  The inconsistency of the review process is maddening.  Admittedly all of us new producers are putting quite a strain on the agents doing the reviews, but in a case like this we are being genuine.  The gin is literally barrel aged for x months.  How is that trying to be misleading?

grrrr

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For the specific reasons noted by others about COLA rejections for using any terminology with "aged" for Gin we went with "Barrel Finished" right on the front label and it was approved in a three week period.

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On June 28, 2016 at 11:13 AM, rtshfd said:

I've seen many bottles that explicitly say "barrel aged" and an age statement of "aged for x months."  The inconsistency of the review process is maddening.  Admittedly all of us new producers are putting quite a strain on the agents doing the reviews, but in a case like this we are being genuine.  The gin is literally barrel aged for x months.  How is that trying to be misleading?

grrrr

By the way, when you say you have "seen many bottles" do you mean you saw the approved COLA from the TTB? I have "seen many bottles" that are modifications of pre-existing approved labels, but have not actually been approved with new COLA.

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On ‎6‎/‎28‎/‎2016 at 3:31 PM, sonnyk said:

For the specific reasons noted by others about COLA rejections for using any terminology with "aged" for Gin we went with "Barrel Finished" right on the front label and it was approved in a three week period.

Did you have to submit a formula for this?  I'm trying to find this out for our barrel-aged gin.  Luckily, the turnaround time for Formula approvals right now is 1 day, so even if I do have to submit a formula, it won't slow me down much.  BUT, I'm worried that if I submit a formula, it will become a Distilled Spirits Specialty, and they won't even let me call it a gin at all... Is anyone else submitting formulas for their barreled gins?

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After four years of selling a gin finished in a variety of different barrel types, all of which received COLA approval as gin, we decided to change our label. This new label (but the same gin) failed. The formula reviewer decided it MUST be classified as "Distilled Spirits Specialty". So the COLA could no longer be passed as GIN. I'm calling them now, and will report back here what I learn.

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Nothing in the gin regulations prohibits aging in barrel, nowhere nohow, so it should never have to be specialty. But if something in your label suggested to them that juniper is no longer the dominant flavor, for example, that would cause it to be a specialty. I have had gins that I would claim don't have sufficient juniper in them to really be called gins.

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On 8/12/2017 at 7:46 AM, bluestar said:

Nothing in the gin regulations prohibits aging in barrel, nowhere nohow, so it should never have to be specialty. But if something in your label suggested to them that juniper is no longer the dominant flavor, for example, that would cause it to be a specialty. I have had gins that I would claim don't have sufficient juniper in them to really be called gins.

Update: Although the regulations don't say anything about aging/not aging gin in barrel, the COLA officials have told me multiple times that if a gin is aged in barrel, it's no longer a gin, it's a distilled spirits specialty.  We tried to get our label passed with a formula attached, calling it Barrel Gin and including a statement of composition as Gin Finished in American Oak Barrels, but they said that "Gin" can't be in the fanciful name because it's not really a Gin, it's a DSS... So we're still working on the label.  The thing I hate about some of these regulations is that they're trying to make it so the consumer isn't misled, but sometimes by doing that, the label ends up being more misleading (or at least confusing) than it was before!  

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1 hour ago, jb789 said:

Update: Although the regulations don't say anything about aging/not aging gin in barrel, the COLA officials have told me multiple times that if a gin is aged in barrel, it's no longer a gin, it's a distilled spirits specialty.  We tried to get our label passed with a formula attached, calling it Barrel Gin and including a statement of composition as Gin Finished in American Oak Barrels, but they said that "Gin" can't be in the fanciful name because it's not really a Gin, it's a DSS... So we're still working on the label.  The thing I hate about some of these regulations is that they're trying to make it so the consumer isn't misled, but sometimes by doing that, the label ends up being more misleading (or at least confusing) than it was before!  

Simply wrong, at least for the past few years. Also, the regulations say something SPECIFICALLY about aging gin in a barrel:  

(d) Other distilled spirits. Age, maturity, or similar statements or representations as to neutral spirits (except for grain spirits as stated in paragraph (c) 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.

So, it doesn't say you can't age or store it, just that you can't make a statement or representation as to age or maturity. There are dozens of counter examples out there of gins that have been stored in barrels and allude to it in other ways, including 3 of our products. This would be tantamount to saying that you can't store it in a specific container, which is nonsense. What you can't do is say that the product is aged. Talk to a TTB manager. I suspect either you have a novice officer giving you bad feedback, or that there is something else in your formula or label that is tripping the requirement for distilled spirits specialty: for example, if you say your are flavoring or aging the product with oak after production, that becomes a flavored gin or a distilled spirits specialty. Don't say that.  I am not surprised the phrases you suggested would not be allowed. Composition can say nothing about barrels (suggests aging), you can not use a fanciful name with it either. But you can add a general label text that can allude to it. We have been able to use "Barrel Reserve" on a few of our labels, including gin, where an aging statement can otherwise not be made.

By the way, specialties can't be represented as "aged" either, per the reference above. So, storing the product in barrel can not be the discerning point for separating a gin from a distilled spirit specialty.

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Every time I see you US distillers trying to satisfy your label requirements I am glad I am an Aussie.

I have a desktop printer and rolls of my generic labels. Whenever I make a new product I run off a few labels with the name of the product and a description.

As long as the information on the label is truthful, has bottle size, ABV and number of "standard drinks" then all is good.

(The main down-side to being an Aussie distiller is the rip-off excise tax we pay.)

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It is late and I am tired, but I'll offer a comment.  

If TTB insists the product does not meet the gin standard,  i.e., that the finishing in a barrel alters, in its opinion,  the class and type under 5.23,  I think the specialty requirement at 5.35 does not preclude you from mentioning gin in the required statement of composition.  In fact,. I might go so far as to argue that omitting reference to gin would render the statement inaccurate and untruthful.

I think, if pressed, TTB would concede that there is what TTB would call a  long standing precedent that allows the class of spirits used in a specialty to appear in the statement of composition.  For example, look at products like Angel's Envy products.  They have a whiskey reference, but are classified as specialty items.  You can verify that by looking at the public COLA database TTB has on line.

The prohibition that I think the label specialist is twisting  also appears in 5.35.  It states, "A product shall not bear a designation which indicates it contains a class or type of distilled spirits unless the distilled spirits therein conform to such class and type."  I read that to say,  if you include, in the required truthful and adequate statement of composition, a spirit, then the spirit component must have conformed to the standard at the time that you rectified it to create the specialty.  So, for example, the statement of composition, "Rye Whiskey finished in Port Barrels," in the style of Angel's Envy, mentions rye whiskey, even though the finished product is not rye whiskey.  Of course, the requirement presumes that the spirit component was entitled to the rye whiskey designation had it not been rectified.   Further, I think you could have a specialty with a fanciful name like "Frosty Aires" with a statement of composition stating "Gin Blended with Malt Whiskey," as long as the product contained a blend of of gin and malt whiskey.  

However, what I think doesn't matter.  TTB bats last in this game.  Sometimes, however, people win on appeal.  Remember that TTB insisted, over Jack Daniels rightful objection, that an unaged distillate produced from a rye mash,  at 140 proof, was a neutral spirit, because it had not seen oak.  JD was equally wrong, however, in asserting it was a whiskey, but TTB eventually relented, admitting that they had erred in their insistence that the 140 proof distillate was a neutral spirit, stating, in a letter to Chuck Cowdery,  "A product that is made from fermented mash of grain and produced at less than 190° of proof but not stored in oak containers would be a distilled spirits specialty product, as it would not meet any of the standards of identity."  In that case, by the way, whiskey could not appear in the statement of composition, as I read the rule TTB seems to be citing in the case of the gin at hand, because the spirits component was not whiskey, it was alcohol distilled at less than 190 proof, at least as I see it.  But again, I don't matter, even if I'm right :-).  

 

 

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On 8/18/2017 at 1:40 AM, dhdunbar said:

If TTB insists the product does not meet the gin standard,  i.e., that the finishing in a barrel alters, in its opinion,  the class and type under 5.23,  I think the specialty requirement at 5.35 does not preclude you from mentioning gin in the required statement of composition.  In fact,. I might go so far as to argue that omitting reference to gin would render the statement inaccurate and untruthful.

 

 

In fact, the TTB told us exactly what you said.  We need to state the composition as Gin Finished in Oak Barrels, according to our formula.  However, we have to come up with a fanciful name that doesn't include "Gin" in it, and nowhere else on the label can it mention Gin.  That's what I have a problem with.  A fanciful name that doesn't include Gin could just confuse the customer more, plus it doesn't coordinate with our standard Gin label.  On top of that, how are so many other distilleries able to include Barrels, Oak, Finished in Oak, etc. clearly on their Gin labels and we can't?  It's really frustrating.

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I can't advise you of what TTB will approve, but look at the Angel's Envy label on TTB's COLAs Online website.   I would say that it is creative, on both the bottlers and TTB's part.   TTB calls Angel's Envy a whiskey specialty.   There are bourbon and rye specialty labels approved, something like 18 COLA's in all.  Let's consider the label of one whiskey specialty - as TTB designates it - composed of rye whiskey finished in rum barrels.  

TTB considers "Angel's Envy" the brand name, and a statement, "From the Cellars of Lincoln Henderson" the fanciful name.  TTB does not state what it considers to be the truthful and accurate statement of composition.  But if we look at the information on the brand label, where the class and type information must appear, we can reach some conclusion about the stretch TTB is prepared to make.  The information runs down the label as follows:

 

From the Cellars of

Lincoln Henderson

Angel's Envy

Finished Rye

Rye Finished in

Caribbean

Rum Casks

We know, because the database tells us so, that the two lines, "From the Cellars of Lincoln Henderson," is the fanciful name.

We know, again because TTB tells us so, that "Angel's Envy" is the brand name.

I do not know what TTB makes of the phrase "Finished Rye."

So, by default, "Rye Finished in Caribbean Rum Casks" becomes the truthful and adequate statement of composition.

Now, if you look at reviews by people who are suppose to know a thing or two about whiskey, they review Angel's Envy as whiskey, not a specialty.  If the label says Bourbon aged in port, they review it as bourbon.  No one is deceived about what they have and no one cares that TTB  says it is a specialty,  not whiskey.  That may suggest some solutions to how gin "finished" in barrels can be marketed as gin without a claim that is offensive to TTB.

  

 

 

 

 

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