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COLA flavored whiskey problem

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Working on developing a flavored whiskey made with unaged light whiskey. aka whiskey distilled to 180, not aged but flavored with natural ingredients. My goal is for the spirit to be clear.

 COLA had kicked back my label on flavored whiskey due to the fact that there in not a oak storage component to the spirit being used. Has anyone out there produced a spirit like this? How did you get around the oak storage component?

 

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You don't in order to be called a whiskey it has to touch an oak barrel you can distill right thru the barrel  but you have to have an aging statement on the front

of the label other then if you does not touch a barrel it's only a moonshine

 

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I believe I've heard of the 'five second rule' somewhere. Basically what Tall Ship said, have it touch oak and accurately state how long it did so. You can understate, never overstate contact time.

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I believe corn whiskey does not have to be aged, but I would have to go back and read the bam again to be sure. As others have said the definition of whiskey is that it's been on oak and most have to be distilled to no more than 160 proof.   But you may be able to get away with what you want if it's corn only. 

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to summarize:

1) corn whiskey does not have to be aged, or aged in new uncharred or used cooperage, but it must be distilled under 160 proof, you must state the age on the label (under 4 years).

2) light whiskey is over 160 but under 190 proof, must be aged in new uncharred or used cooperage, you must state the age on the label (under 4 years).

3) the flavored whiskey can be bottled at lower proof (60), but it is now a different class, and will require a formula. sugar may be added, flavorings must be natural (artificial flavor makes it imitation distilled spirits).

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The trick is to not specify a type of whiskey. Your 180 proof unaged spirit fits the TTB definition of "Whiskey" and as long as you don't claim a specific type, there's no issue. 

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Quote

 

CORN WHISKEY: Whisky produced at not exceeding 80% alcohol by volume (160 proof) from a fermented mash of not less than 80 percent corn and if stored in oak containers stored at not more than 62.5% alcohol by volume (125 proof) in used or uncharred new oak containers and not subjected in any manner to treatment with charred wood

LIGHT WHISKY: Whisky produced in the U.S. at more than 80% alcohol by volume (160 proof) [but less than 95% alcohol by volume (190 proof)] and stored in used or uncharred new oak containers.

 

So yours a product that falls between the cracks ; at 180pf, is too low for neutral spirits, and too high for any TYPE of grain distillate EXCEPT light whiskey, BUT you must store light whiskey in used or uncharred barrels. The CLASS is WHISKEY as TNJustin suggests, except ... 

Quote

WHISKEY: Spirits distilled from a fermented mash of grain at less than 95% alcohol by volume (190 proof) having the taste, aroma and characteristics generally attributed to whisky and bottled at not less than 40% alcohol by volume (80 proof)

The "characteristics generally attributed"  may be problematic, since only corn whiskey doesn't require wood, and it requires a lower proof at distillation to retain the corn character.  In the US "light whiskey" was generally meant for blending and requires a some limited wood, so AFAICT there are no generally accepted characteristics for this as a separate beverage (tho' there are a few in the market).

==

You could store it in uncharred or used barrels (no minimum time required) and then lawfully call it "light whiskey".  That's a pretty inexpensive approach, and gains you the "light whiskey" label. I don't know about a 5 second rule, but someone (don't recall) has a label proudly states their bourbon is aged in barrel for 60 seconds !

You can label the product source the same as other white dog products, like "unaged corn distillate" or whatever.   Somehow Heaven Hills Trybox white dogs used "New Make" in large letters and "whiskey straight from the still" in small letters.  If the TTB still buys that you might get "UNaged grain distallate"  "light whiskey straight from the still".

 

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Keep in mind, there are illegal labels out there, so don't assume because you found a label out there, you can do the same thing. TTB doesn't have to make the same mistake twice.

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K' and don't you assume the TTB won't make more dubious rulings in the future !   Sometimes in your favor.

IIRC someone (Cowdery?) noted the Heaven Hill use of "whiskey" on their unaged new-make labels.   Someone else (Jack Daniels?) got away with a similar gaffe on a white product too .

I think the Chapter4 categories are fine as typical uses of the terms, but IMO the point of the label reqs should be to accurately inform the consumer - to avoid deception.  They don't currently do that.    Some of those abuses of the definitions (like a 60 second barreling then calling it bourbon) is IMO blatant consumer abuse.  The OPs quest to use the "whiskey" term on unaged highly distilled  product  is similarly dubious - tho' no one should care greatly in a flavored beverage (IMO)

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1. the whiskey has to come to rest. "stop moving" so it can't pass through a barrel.

2. we did over 20,000 gallons of cinnamon, and spiced apple WHISKEY last year. It is in the wording you use and process in how you "use" your alcohol.  :-0)

all of you are thinking about this way to hard........ just saying.

 

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I take it that the overthinking is because of TTB Ruling 2016-3?

Quote

Essential components: When harmless coloring, flavoring, or blending materials are an essential component part of the particular class or type of distilled spirits as described in the standards of identity, their use does not change the class or type of the product. An example is the use of flavors in a class 9 flavored brandy, flavored gin, flavored rum, flavored vodka, or flavored whisky.

My paranoia stems from Chapter 4 only defining the general 'flavored whiskey' class but not saying anything about sub-classes. Given that major distilleries have flavored whiskies with sub-types (e.g., Jim Beam's Red Stag infusions) I suppose that flavored whiskey is more of a modifier than a monolithic class?

Dehner, may I ask what sort of wording and "use" you gave the TTB?

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I just want to throw it out there that my limited experience with FONL and COLAS online has shown me that people here on this site often know more about the TTB manuals then the specialists we are assigned to. So it's possible there might not be anything wrong with your formula or label application. I just went through 2 months of hell trying to get a formula and label approved. Only approved after finally being assigned to a second specialist who correctly read their own manual. Just saying.

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