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Roger

Topping off barrels

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On 12/13/2017 at 11:42 AM, Roger said:

Results:

The product has been rejected for the following reasons:
 
   

Formula not required per 2016-3 - This distilled spirit product does not require formula review nor sample analysis. You may proceed to Labeling. [See TTB Ruling 2016-3]
Additional Description - This whisky does not require formula review.

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Actually, now that I read the response carefully, I see it does not really answer the question. It tells you that you don't need a formula. It does not answer what age you have to put on the bottle. Why? Because even if you do what you propose, the resulting product is still whiskey, and so your COLA can be submitted without formula. But it does not tell you if your COLA can have an age statement that includes time beyond when the water is introduced, the specific question you were asking. I think you need to query the COLA folks on this, not the formula folks.

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2 hours ago, bluestar said:

If you are saying that any addition of water will not stop the aging clock, as I mentioned before, that can not be right in ALL cases. If sufficient water is added so the gauged product no longer meets the requirement of a whiskey (below 80 proof) say, then the category/type has changed. So it must now become about how much water is added. Never mind the difficulty of trying to gauge in a barrel (get accurate proof and volume or weight) without removing it (which would stop the clock).

Nope - There is no minimum or maximum proof that is in a barrel. There is a maximum proof that can be initially put into the barrel, and a minimum proof that can be bottled and called whiskey, but those are completely different issues. There are currently products on the market such as Bookers Cask Strength Bourbon at 130 proof. How's that, you say ? I would think it's because they would merely use product that was put in a barrel at under 125p, allow sufficient angels share H2o evaporation,  then dump and cut to 130p (or not). 

Following that logic, that if you initially filled at 70p, by the time it was straight, at 5% loss per year (+/- 50% Spirit/H2o) you would certainly be above minimum bottling strength. At no time are your required to reguage a barrel during the aging process, as to do so would mean that you would constantly be changing your inventory based on angels share evaporation (or not).

And lastly on the formula issue, as I mentioned in the beginning, I was advised by COLA, to submit the request to FORMULA, which i did.

 

 

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