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So I want to release a white whiskey, I submit my label to ttb and they come back with:

Your product requires an age statement to appear on your label. It must include the length of time in one of the following formats: 4 years old; 6 months old; Aged 4 years; Aged at least 4 years; Aged a minimum of 6 months; Over 2 years old; Aged not less than 2 years; 60% whisky aged 4 years; 70% whisky aged 2 years. 27 CFR 5.40

I want it to be a white whiskey shine product I don't want to age it, that takes away from the point. I cant call it corn whiskey as it is less than 80% corn in mash

 

how do I address this?

 

 

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Call it something else other than whiskey and submit a formula under distilled spirit specialty.   Unless it's corn whisky it has to be aged to be called whiskey and if aged less than 4 years requires an age statement as you found out.  

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Find some used barrels, age it for one day. It'll still be clear and you can legally call it whiskey (whiskey made from a bourbon mash).

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11 hours ago, bluefish_dist said:

Call it something else other than whiskey and submit a formula under distilled spirit specialty.   Unless it's corn whisky it has to be aged to be called whiskey and if aged less than 4 years requires an age statement as you found out.  

See below, house spirits white dog whisky , they don't show an age statement on their bottle, how do they get away with it?

House-Spirits-White-Dog-Whiskey-300x350.jpg

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6 hours ago, Huffy2k said:

Find some used barrels, age it for one day. It'll still be clear and you can legally call it whiskey (whiskey made from a bourbon mash).

so what would I put on the age statement in that case? Aged 1 day ?

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1 hour ago, Georgeous said:

so what would I put on the age statement in that case? Aged 1 day ?

Correct

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Something to keep in mind, just generally, not specifically about the label posted above.

Just because someone managed to get a label through approval doesn't mean it's the label is correct, following regulations, is not misleading, etc.  It also doesn't mean that what a distiller put in the bottle, matches what the label expected to be put in the bottle.  There are plenty of misleading labels that don't follow regulations.

 

 

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I have seen a few whiskeys that don't have age statements and they are under 4 years aged.  That doesn't mean it's right.  It just means no one has caught it.  

If you want it to be whiskey and be white, put something like aged 1 day and then always age it more than 24 hrs.  You are covered.  

My whiskey and bourbon labels were approved without an age statement as they do not require one if aged over 4 years.  I added one as we are selling bottles that were aged less than 4 years.  

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The House Spirits example was also approved probably 10+ years ago, so there has probably been some turn-over and clarifications to the approval process. 

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If you don't put an age statement on the label  , COLA assumes it is 4 years or older. So they pass it until they find out otherwise.

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3 hours ago, bluefish_dist said:

I have seen a few whiskeys that don't have age statements and they are under 4 years aged.  That doesn't mean it's right.  It just means no one has caught it.  

If you want it to be whiskey and be white, put something like aged 1 day and then always age it more than 24 hrs.  You are covered.  

My whiskey and bourbon labels were approved without an age statement as they do not require one if aged over 4 years.  I added one as we are selling bottles that were aged less than 4 years.  

So does sticking a stave in my blending barrel for a day count as aged 1 day?

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23 hours ago, Silk City Distillers said:

No.

why not? I just spoke with ttb and they told me if I poured through a trough from one vessel to another it has touched oak and I can put an age statement on it. She recommended aged less than 1 minute. So what would be different of a trough or a stave for that matter? Hell what about an oak stir stick my wife calls a mop handle? :D
 

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58 minutes ago, Georgeous said:

why not? I just spoke with ttb and they told me if I poured through a trough from one vessel to another it has touched oak and I can put an age statement on it. She recommended aged less than 1 minute. So what would be different of a trough or a stave for that matter? Hell what about an oak stir stick my wife calls a mop handle? :D
 

That answer from the TTB makes no sense and seems like a very loose interpretation of the word "aging".

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3 hours ago, jackb1050 said:

vessel/ container is different than a stick    read the standard "oak container"

so why is it ok to run it through a oak trough and say aged

 

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35 minutes ago, Georgeous said:

so why is it ok to run it through a oak trough and say aged

 

It’s not, read the CFR. 

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so filling a used oak barrel then emptying it is ok? I don't get these regulations

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Yes, read the CFR... https://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=3e62d2aa84281f69f653de44f5e52f81&mc=true&n=sp27.1.5.c&r=SUBPART&ty=HTML#se27.1.5_122

If you don't meet the requirements for corn whiskey below, then you have to meet the requirements of some other whiskey. Likely you will want to use 'whiskey distilled from..."

(ii) “Corn whisky” is whisky produced at not exceeding 160° proof from a fermented mash of not less than 80 percent corn grain, and if stored in oak containers stored at not more than 125° proof in used or uncharred new oak containers and not subjected in any manner to treatment with charred wood; and also includes mixtures of such whisky.

(2) “Whisky distilled from bourbon (rye, wheat, malt, or rye malt) mash” is whisky produced in the United States at not exceeding 160° proof from a fermented mash of not less than 51 percent corn, rye, wheat, malted barley, or malted rye grain, respectively, and stored in used oak containers; and also includes mixtures of such whiskies of the same type. Whisky conforming to the standard of identity for corn whisky must be designated corn whisky.

You will notice it says stored in used oak containers, no minimum age is stated, but age statements are required for less than 4 years of age on all whiskeys. And before you say 'it says container, not barrel', an oak container is a barrel.

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2 hours ago, Georgeous said:

so filling a used oak barrel then emptying it is ok? I don't get these regulations

i am not attempting to be rude but you need to "get" these regulations, comply, and, understand them completely if you want to stay in business.

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4 hours ago, MGL said:

i am not attempting to be rude but you need to "get" these regulations, comply, and, understand them completely if you want to stay in business.

no offense taken MGL as I have read them cover to cover. it is just that what is written, what is approved, and what is interpreted leave a lot of room for ambiguity. Which are the points I am trying to understand. TTB labeling person on phone tells me all it has to do is touch oak, well that aint what the BAM says right? These are the points I am trying to raise and get clarity

 

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I’d ask for that interpretation in writing, the phone call sounds even more ambiguous than the regulation.  To me, interpreting the situation, “touching oak” means going in a barrel.

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so those who use staves only in a blending tank, what can you call it? According to this thread it aint whisky? But many sell that as whiskey that I have seen.

 

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25 minutes ago, Silk City Distillers said:

To me, interpreting the situation, “touching oak” means going in a barrel.

I dont have the BAM in front of me but I dont believe it ever mentions "barrel", but rather "container". Could that be an exploited loophole??

 

 

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I understand this being an issue when barrels were scarce and hard to source because nobody had additional capacity, and it was nearly impossible to get a call back from a barrel manufacturer.  You can pretty much get barrels from anyone in a week time.  Not following why this is still a problem to be solved?

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