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Roger    23

I just had a COLA for a Distilled Spirits Specialty kicked back for the 2nd time because I put on the label :Distilled from Wheat. TTB insists that because a product source is not required on a DSS, that to put one on, is potentially confusing to the customer. This is the 2nd of two (so far) identical products (vodkas infused with natural ingredients) and the first one which is identical in formulation and labeling (except different natural flavor ingredients) is 6 months old, and on that label the TTB demanded that I put Distilled from Wheat on the label  :(

Because we distill our NGS/Vodka from grain and/or fruit in house it would seem that as all vodka is NGS and all continuous distillation of NGS follows: §5.39   Presence of neutral spirits and coloring, flavoring, and blending materials  - (2) In the case of neutral spirits or of gin produced by a process of continuous distillation, there shall be stated the name of the commodity from which such neutral spirits or gin have been distilled. The statement of the name of the commodity shall be made in substantially the following form: “Distilled from grain”, or “Distilled from cane products”, or “Distilled from fruit”.    From that, one could infer that the first TTB agent got it right for the first label, and the 2nd one got it wrong ?

In todays hyper conscious society of food allergies, particularly with Gluten sensitivity (whether viably carried through Azeotrope or not) we have always felt that it is best to advise our customers of the base ingredients. I believe the TTB allows distillers to claim "does not contain gluten" on products that are corn based. It seems strange that they would allow a distiller to advertise that their products are "gluten free" but not allow distillers who are being conscientious, to alert their potential customers of something that they may have either a real or physiological aversion to.

Has anyone received label approvals for DSS's where this has come up, one way of the other?

tks

 

 

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Without doubt the hardest label I have done has been for our unaged bourbon, a white whiskey if you will.  Had to do formula for it.  Had to jump through hoops with the label for it.  Now, had I stuck it in a new barrel for 1 day it would have become sooooo much simpler.  Same distillate, but no formula required and the label is about as straight forward as it can be.  Go figure.

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It should say spirits distilled from wheat.   All you are missing is the spirits.   We have a DSS and it reads spirits distilled from corn and cane sugar, below the fanciful name.  Just went through this a couple of weeks ago where I had distilled from instead of spirits distilled from for my blue agave. 

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JNorris    0

Roger - You can ask that the pending COLA be reviewed be a QC or QA analyst (I don't remember what they call them).  I believe I had to send an email to them and ask for a review based off of a prior label approval.  Of course, as with any TTB questions, you pose the risk of them coming back with differing answers and then possibly both labels having issues and being rejected.  In the email, be nice and detail all of your concerns and specify IDs for both COLAs.  Good luck.

alfd@ttb.gov

 

 

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