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Sator Square Distillery

Pomace Brandy required labeling statement

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I have a question about labeling regarding pomace brandy that may have come up for some of your before. I understand that if you're aging it for less than 2 years, that a statement of age is required on the label. But if it isn't aged at all, would it simply be considered a grappa instead, and not require any statement of age?

I want to label our bottle as a pomace or marc brandy, not a grappa. The guidance is somewhat vague to my reading. What is the appropriate labeling on an unaged pomace brandy?

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We went back and forth a bit with them but finally gave up and just put a line on the side "4 months old" and as long as it's at least that we're good. We let ours sit much longer anyway before bottling.

If you want to get sticky "Grappa" is name protected in the EU at least, though some others seem to use it anyway. We just use it as a verbal reference in the tasting room for unfamiliar folks.

 

Good luck.

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From the CFR:

5) ‘‘Pomace brandy’’, or ‘‘marc brandy’’, is brandy distilled from the skin and pulp of sound, ripe grapes, citrus or other fruit, after the withdrawal of the juice or wine therefrom, and shall be designated as ‘‘pomace brandy’’, or ‘‘marc brandy’’, qualified by the name of the fruit from which derived. Grape pomace brandy may be designated as ‘‘grappa’’ or ‘‘grappa brandy’’.

So grape pomace brandy and grappa are the same, from TTB point of view. TTB does not limit term grappa in US like EU. And:

Fruit brandy, derived from grapes, shall be designated as ‘‘grape brandy’’ or ‘‘brandy’’, except that in the case of brandy (other than neutral brandy, pomace brandy, marc brandy or grappa brandy) distilled from the fermented juice, mash, or wine of grapes, or the residue thereof, which has been stored in oak containers for less than 2 years, the statement of class and type shall be immediately preceded, in the same size and kind of type, by the word ‘‘immature’’.

So you do not have to have the immature designation for pomace-marc-grappa brandy if aged less than 2 years. No statement of age is required, but as is usual, any statement of age has to be true, which means it must indicate the minimum time the product was aged in oak containers. Aging or not does not affect the use of the term "grappa" for grape pomace brandy, and in Europe, there are many barrel aged grappas.

So to your original point, you can call it grape pommace brandy, marc, or grappa, the terms are interchangeable. You do not have to label it immature if aged less than 2 years, as you would for regular grape brandy. You do not have to state age, but if you do, it must be truthful, identifying the minimum time spent in oak container for any product in the bottling. So the appropriate description for unaged pomace brandy is pomace brandy or unaged pomace brandy. Or marc. Or grappa.

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