class/type 'Whisky Specialties'?

[clearwaterbrewer]

OK, if you make a flavored whisky/whiskey, logic would seem to say you would create a formula for Class/Type Flavored Whisky and when you did the label you would pick a formula of the Class/Type 'Flavored Whisky''  I have one COLA for this class/type in for approval, but after my headaches with flavored vodka label, I do not expect it to get approved first time..

However my little experience in the real world shows that does not seem to be true..

An existing product we all know of (COLA 10146001000306 ) uses the fanciful name of 'cinnamon whisky' and the Class/Type of 'whisky with natural cinnamon flavor' on the label, In the actual COLA it says Class/Type is "Whiskey Specialties"  and in the COLAS documentation, I see  "641 Whisky Specialties"  

1 - There is no actual formula class/type entry for that 'Whisky Specialties', only for "Distilled Spirits Specialty",  is there a link or direction from the TTB that says this correlation exists?

 

2 - do DSP's generally shy away from 'flavored xxxx', and just use DSS?

3 - Does this allow one to skip the BAM requirements for wood chips? It seems to... but 'whisky' is on the label of the DSS product in two places... 

From the BAM:

8. TREATMENT WITH WOOD · DISCLOSURE “COLORED AND FLAVORED WITH WOOD _________” (insert chips, slabs, extracts, etc., as appropriate) is required on labels to indicate treatment with wood · APPLICATION Applies only to whisky and brandy treated – other than through contact with oak containers – with wood: -In any manner or form, either directly or indirectly, e.g., chips, slabs, extracts, etc. -At any point during the production or storage process, up to and including the time of bottling