TTB Vodka definition

[porter]

Probably an easy answer, but I can't find it.

The TTB definition for vodka is 'distilled at 190p' or 95% pure alch. And that isn't much of a yield from a 50gal batch at 15% starting. So where's the profit?

Does that mean you don't take anything from the batch below 190p ? That's what I take it to mean. But it doesn't make much sense.

I understand the 'clear, tasteless' virture of TTB definition vodka, but what to do with the rest of the wash?

Wouldn't I simply keep on cooking and take everything below that for a whiskey or brandy?

I understand you can use the rest to recharge the next run of vodka, but that's not the question here.

[will]

just for starters, let's do the math:

50 g @ 15% = 7.5 g pure alcohol. bottled at 80 proof, that's ~18.75 gallons. at ~5 bottles per gallon, it's ~94 bottles. even at $15 per bottle, it's nothing to sneer at. much more fun with a bigger still, though.

YMMV - those numbers are theoretical, not actual, but never underestimate the power of compound interest, nor the power of dilution.

a properly operating vodka operation will not waste much alcohol, but the trick is in understanding how a column will perform successive "distillations" in each of the plates on the way up, thus most of the alcohol in the wash is available for product. it's all about the reflux. often, multiple distillations are performed on the way to 190 proof...at least two: stripping and finishing.

the TTB definitions carefully and clearly define the nature and character of the classes and types of products. note that "alcohol" and "vodka" are different. both are made from any material and taken from the still at 190pf or higher, but vodka has four additional constraints: it must be free of (1) character, (2) aroma, (3) taste, and (4) color. (21cfr5.22(1)a). except for color, these definitions are subjective, and therefore somewhat broad.

will

[porter]

Will, great answer. However, the numbers stated I am already aware of. And the mention of what the TTB defines are understood. Good explaination on your part though.

But the question still is unanswered. What is customary to do be done with the rest of the wash below the 95% mark?

Is it always added to the next wash, or what?

Along that line, if a reflux column has 7 plates, and each plate is considered a "distillation point", then can it be said the end product of a single spirit run through has been "distilled 7 times"? Or is there a true TTB definition of what "distilled" means? I have a valid reason for asking this, please bare with me.

[will]

when a column takes a vapor to 95%, the wash may be well below 5% (even below 1%) depending upon the performance of the column, so it does not follow directly that there's lots of alcohol in the kettle to worry about. no, it's not customary to add that stillage to the next wash because that would simply dilute the wash even more.

if the kettle/column combination is not able to continue to deliver spirit at 95% midway through the run, then one may well choose to capture that spirit in a second container, and add that back to the next kettle charge....but that's a band-aid for a different problem...or a different limitation of the equipment.

i don't know of a TTB definition of "distilled x times," but no, that's not "distilled 7 times" - it's distilled only once.

in the case of a four-column continuous still, one is free to advertise that spirit as "distilled 4 times" even though not all the spirit will have passed through all four of the columns.

keep digging - keep reading,

will

[daveflintstone]

Will, great answer. However, the numbers stated I am already aware of. And the mention of what the TTB defines are understood. Good explaination on your part though.

But the question still is unanswered. What is customary to do be done with the rest of the wash below the 95% mark?

Is it always added to the next wash, or what?

Along that line, if a reflux column has 7 plates, and each plate is considered a "distillation point", then can it be said the end product of a single spirit run through has been "distilled 7 times"? Or is there a true TTB definition of what "distilled" means? I have a valid reason for asking this, please bare with me.

If you have a "valid reason for asking this", why don't you state your reason? Better yet, why don't you read some books on distilling; it seems you have precious little knowledge of the subject. I'm not being snooty; I was at your stage not too long ago and perplexed by the process. A simple distilling book will clear up much for you. Also, once again I say if there's a question for the TTB (after you understand the distilling process), call and ask them. They like to help.

[porter]

The valid reason for asking is to gain knowledge of the process as based on what the TTB wants. There are several vodkas which advertise such as "...Distilled 7 Times...". So what does that mean by TTB definition? The apparent answer is, nothing, other than implied purity.

WILL, you are a true mentor on the board, at least to me you have been. Your answers are direct and knowledgable.

DAVEFLINTSTONE- What I'm asking isn't found in the books. And the TTB, however much you love them, doesn't have things published on this particular question, just what a finished vodka is, not how to label it based on how many runs.

Experience with the process?? How about computing surface area of reflux units to see the effiecenty on reflux, or understanding the theoretical maximum you can achieve by normal distillation of ethynol is 96.4%, the azeotrope of alcohol. Or the fact you can achieve complex aging flavors by mixing your charred oak with toasted cherry and apple wood while aging in stainless (much more controllalbe)....Yes, direct experience with all the above and more.

Please, if you didn't like my question, you didn't have to be condescending about it, just don't answer it.

[will]

Don't be concerned with the "tone" of some of the answers you'll get. I get my nose out of joint too. Tomorrow well all forget...

I'm not the TTB, but my take on it is that if you depart from the normal production processes such as aging in stainless with chips of wood, then be prepared to produce a formula, and make statements on the bottle.

It won't be whiskey when you're done, unless it has been stored in oak, and if it has been treated with other flavorings, even infused with the same type of wood that it was stored in, that fact will have to appear as part of the labeling. You can't pull the wool over the eyes of the consumer.

I think that the "distilled n times" claims are somewhat truthful in many cases. I'm just not convinced that each pass did anything.

Will

[Wilder]

Some of the TTB reg don't make a lot of sense to me. 80 or 120 proof what is the difference if the taste of the spirit is of a quality nature. The comsumer is not getting 60 proof that is advertised and 100. The proof should be in the PROOF.

[Scott @ Twenty2Vodka]

The TTB actually does like to help. The broad nature of distilling is why they don't publish everything in the code of federal regulations, although the shear volume makes it appear that they tried. Also important to note that 27 CFR 19's purpose is "protection of the revenue" (where revenue=excise tax), a phrase they use many many times. If you call them or email them directly, they will likely give you a finite answer to your specific concern with little tooth-pulling.

-Scott

[Jonathan Forester]

Porter- I think you are coming from the pot still / home distilling background. Using a column is a very different creature than a pot still. Basically all the ethyl alcohol is available in a column still, while only a percentage is available with a pot still.

Probably an easy answer, but I can't find it.

The TTB definition for vodka is 'distilled at 190p' or 95% pure alch. And that isn't much of a yield from a 50gal batch at 15% starting. So where's the profit?

Does that mean you don't take anything from the batch below 190p ? That's what I take it to mean. But it doesn't make much sense.

I understand the 'clear, tasteless' virture of TTB definition vodka, but what to do with the rest of the wash?

Wouldn't I simply keep on cooking and take everything below that for a whiskey or brandy?

I understand you can use the rest to recharge the next run of vodka, but that's not the question here.

[porter]

Porter- I think you are coming from the pot still / home distilling background. Using a column is a very different creature than a pot still. Basically all the ethyl alcohol is available in a column still, while only a percentage is available with a pot still.

I think we all come from the 'home pot still' at some point. You are correct in that regards.

As for a column still, I understand have used the reflux units, so I do understand the process. I guess the primary reason I've never run a column as a production unit is that vodkas don't realy interest me for taste. However, to get more cashflow it looks like you need to run some form of 'spirits' though. I'm really looking at rye spirits. From what I've researched though it looks like it needs to be run exactly like vodka, at 190+, in order to qualify as a spirit drink. that's the reason for my inquiry.

Any input on that would be appreciated.

[will]

Porter,

The Spirit BAM has been unavailable for some time, but it's still on the TTB site at:

Spirit BAM though you'll have to assemble it yourself.

190 proof is a dividing line in the CFRs. Anything that runs at 190pf or higher will be Alcohol.

Any Alcohol that has been further processed by additional distillation or treatment with charcoal may be Vodka if it fits the four requirements stated, BUT anything that has been distilled to 190 or higher may not be anything else, only Alcohol or Vodka...it can't be a Rye Spirit. It might be a Distilled Spirit Specialty (the catch-all), or used in a formulated product.

As a refinement of earlier posts, stills are divided into two broad classes: Charge and Continuous, and each can have a column or not. Continuous stills don't have a kettle, while charge stills do...and charge stills can have columns...and some simple "strippers" are continuous stills without a column. That's a total of four types of stills. Stripper, Continuous Column, Whiskey/Cognac, and Charged Column. A charged column still may or may not make 190 proof based on how many plates it has, how hard you push vapor off the kettle, how much cooling you can apply to the dephlegmator, and how much ethanol remains in the kettle.

There are plenty of alternatives to vodka for creating cash flow while your spirit matures. Read the BAM and CFRs again. To qualify as whiskey, your grain mash must run at less than 160 proof. If you store it in used containers, it can be Whiskey Distilled from Rye Mash...and there's no minimum on how long it's stored, but if less than 4 years, you'll have to say so. This means you can make "Whiskey from Rye Mash, Distilled in 2010, and aged less than four months in used Bourbon Barrels." Note, however, that once you've used them for your product for whatever length of time, your Bourbon Barrels may no longer be Bourbon Barrels...but they're still Used Barrels.

[porter]

Will=====

I assembled the BAM from the TTB site awhile back, just about dog-eared the thing by now.

And the different stills are understood, although I ruled out continous feed column for anything due to space and limited use, not as versatile.

What's confusing is a product labeled "Rye Spirits". When I inquired whether it was distilled as a 'spirit' class or 'whiskey' class they responded 'both'. Being a clear product I would presume a spirit, or vodka style product. Unless it was filtered after being short-aged on oak, that would give it the clear. Haven't found the product around here to see the label. I recently read the long discussion regarding an India Single Malt product where the TTB doesn't have a designation for single malt, so they wouldn't let them label it as such. The producer won in the end, but I don't want to get into a p.ssing match with the TTB over stuff like that.

Is there anyplace we can look online to see the TTB label applications for various products? I'm not concerned so much what is on them, it's how it's said.

Such as '...aged in oak...' is not the same as '...aged with oak...'.

What it comes down to is delivering what the public will pay for and likes. Wording can always be worked around to meet fed specs, while still being absolutely truthful.

[will]

Porter,

You can browse COLAs at COLA Registry

...but read the CFRs again - Standards of Identity at 27 CFR 5.22

Note the range allowed for proof at time of distillation for various types.

Will

[coop]

I think we all come from the 'home pot still' at some point. You are correct in that regards.

As for a column still, I understand have used the reflux units, so I do understand the process. I guess the primary reason I've never run a column as a production unit is that vodkas don't realy interest me for taste. However, to get more cashflow it looks like you need to run some form of 'spirits' though. I'm really looking at rye spirits. From what I've researched though it looks like it needs to be run exactly like vodka, at 190+, in order to qualify as a spirit drink. that's the reason for my inquiry.

Any input on that would be appreciated.

If you need to make some kind of "cash flow spirits" you might need to look at a "Corn Whiskey". By definition it is a un aged whiskey. You cam put it in used barrels for a short time to give a little color and flavor. Do not use any kind of activated filtering after being in the barrels as it will strip all color and flavor from the spirit. coop

[porter]

Porter,

You can browse COLAs at COLA Registry

...but read the CFRs again - Standards of Identity at 27 CFR 5.22

Note the range allowed for proof at time of distillation for various types.

Will

The COLA link is what I was looking for. Thanks....

Regarding the proof, unless I'm missing something, I understand the 'less than 160' for the whiskeys. That's not the problem. That range is doable either type of still.

The question comes up with their designation:

"(a) Class 1; neutral spirits or alcohol

(2) “Grain spirits” are neutral spirits distilled from a fermented mash of grain and stored in oak containers."

which would mean we need to run a good column to get that level, which we don't want to do.

However, with Wasmund's Rye Spirits, they explain in their pdf product statement they run it at just under 160 in a pot still. But in order to make a clear rye spirit, it needs to be run through carbon filtering after short-aging, and that puts it under the subtractive issue in the TTB of removing color. Unless you simply flash it at the oak as Wasmund's states, "Less than 30 days", so it never picks up anything.

More confusion, they state----"...bottled at barrel strength prior to aging..." When it's bottled it no longer ages, so how do you bottle it then age it?

Sounds like we just need to make a product the way we want, then find out how they want it labeled.

And I just found out in order to do our brandies we need a winery permit (seperate building area also) in order to produce the wine which will only be used to make brandy.

[porter]

If you need to make some kind of "cash flow spirits" you might need to look at a "Corn Whiskey". By definition it is a un aged whiskey. You cam put it in used barrels for a short time to give a little color and flavor. Do not use any kind of activated filtering after being in the barrels as it will strip all color and flavor from the spirit. coop

Not interested in corn whiskey, can't stand to even taste it, and yes I've tried some supposed really good product from several distilleries recently. Appreciate the thought. Might have something to do with my pouring a half empty beer full of corn whiskey too many times way-back-when. Made for good 4wheelin through the creeks though.

Will---Looked at the COLA site, doesn't show what I wanted to see and that's the digital label itself. Thanks for the link though.

[will]

Will---Looked at the COLA site, doesn't show what I wanted to see and that's the digital label itself. Thanks for the link though.

Click on "Printable Version"

[will]

The COLA link is what I was looking for. Thanks....

Regarding the proof, unless I'm missing something, I understand the 'less than 160' for the whiskeys. That's not the problem. That range is doable either type of still.

The question comes up with their designation:

"(a) Class 1; neutral spirits or alcohol

(2) “Grain spirits” are neutral spirits distilled from a fermented mash of grain and stored in oak containers."

which would mean we need to run a good column to get that level, which we don't want to do.

However, with Wasmund's Rye Spirits, they explain in their pdf product statement they run it at just under 160 in a pot still. But in order to make a clear rye spirit, it needs to be run through carbon filtering after short-aging, and that puts it under the subtractive issue in the TTB of removing color. Unless you simply flash it at the oak as Wasmund's states, "Less than 30 days", so it never picks up anything.

More confusion, they state----"...bottled at barrel strength prior to aging..." When it's bottled it no longer ages, so how do you bottle it then age it?

Sounds like we just need to make a product the way we want, then find out how they want it labeled.

And I just found out in order to do our brandies we need a winery permit (seperate building area also) in order to produce the wine which will only be used to make brandy.

Wasmund likely means that it's bottled at cask strength, and it's not aged. His because of his process, he may be in the last class defined in the CFRs - Spirit Specialty.

The class you want to be in is Whisky - you can use charcoal prior to storage, just as Jack Daniels does. You do not have to use new oak, and you can store it for as little time as you like, but you will have to declare any period under four years. If you use any adjuncts such as oak chips, you'll be back in Spirit Specialty land.

Class 2; whisky. “Whisky” is an alcoholic distillate from a fermented mash of grain produced at less than 190° proof in such manner that the distillate possesses the taste, aroma, and characteristics generally attributed to whisky, stored in oak containers (except that corn whisky need not be so stored), and bottled at not less than 80° proof, and also includes mixtures of such distillates for which no specific standards of identity are prescribed.

Remember, this advice is worth what you paid for it.

Will

[grehorst]

And I just found out in order to do our brandies we need a winery permit (seperate building area also) in order to produce the wine which will only be used to make brandy.

Who told you this? Recently a distiller I know was told this in error by someone in the TTB. He went ahead and got a winery permit that it turned out he didn't need. If it was someone within the TTB, contact someone else!

[porter]

Who told you this? Recently a distiller I know was told this in error by someone in the TTB. He went ahead and got a winery permit that it turned out he didn't need. If it was someone within the TTB, contact someone else!

I'm going to start a new thread on this subject. Take a look there as I'll post the article link there.

[will]

Guy,

This might be a state thing rather than a TTB thing. I know we're some kind of winery from the TTB perspective, but don't need to be in CA (though we are anyway).

Will