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White Whiskey


Georgeous

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PeteB.  Read the aussie regulations mate.  I am an Aussie too but I am setting up in Argentina and I have had to find the regulations here.  Now in Argentina they are very very rarely enforced but the TTB wont apply where I am. Neither will the in Tasmania.  

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Can you submit an unaged "whiskey" as a "Distilled Spirit Specialty" and then have it labeled as "Moonshine" or "White Dog"? I know i've seen things labeled as moonshine, but there is no statement of identity for it.

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5 hours ago, adamOVD said:

Can you submit an unaged "whiskey" as a "Distilled Spirit Specialty" and then have it labeled as "Moonshine" or "White Dog"? I know i've seen things labeled as moonshine, but there is no statement of identity for it.

Yes, that is acceptable.  You will have to have a fanciful name, ie “joes special shine” or something not a type of spirit.   You will have to have a distilled from xxxx on the front as well to show what was used to make it.  Ours was made from corn and sugarcane.   Check the Bam for exact wording.  

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If you want a way to not need an age statement. Make use of this rule:

TTB has also had a number of requests from industry members for guidance on labeling products that are stored in two different types of barrels. For example, whisky must be stored in oak containers, in accordance with the standard of identity. When a producer stores the whisky in oak containers and then stores it in a different type of container, such as a maple barrel, the spirit becomes a distilled spirits specialty product and must be labeled with a statement of composition, such as “Bourbon Whisky finished in maple barrels.” TTB proposes, in § 5.155(c), to add this requirement to the regulations.

So put you white whiskey in a barrel for 1 minute, so you can call it a whiskey.  Then introduce a secondary treatment, such as above so that it becomes a distilled specialty spirit.  As such your label can read "Whiskey" in large letters with smaller finished with  XXX.  As a distilled specialty spirit, no age statement is required.  

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@Dmonahan cool tip. I like the flavor of unaged spirits over 160P though so I think I'll just drop the whiskey. For what it is, I think Moonshine or something has better ring to it,  and more transparency than Light Whiskey.

Has anyone been audited by the TTB? What is the consequence of a mislabel? Fine? Shutdown? I know one distillery with "single malt" whiskey that's only been in production 2 years max. I believe it has no age statement. I've seen quite a few violations I won't go into detail about here. Some from distilleries that have been open many years. I've been trying my best to go by the book, but kind of wonder why bother at certain point.

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Yes I know of many that don't quite follow the rules as they should with regards to whiskeys.  My friends at 300 Days of Shine do a nice job with moonshine with some barrel finishing for some of their shine.  They get some great barrel flavors without needing age statements.  Check out their label pic

 

IMG_4973.JPG.46b7f0e1c0c8f8b919636e511110a414.JPG

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I may have missed this conversation on purpose.  

  • TTB makes standards of identity.The standards are in 27 CFR 5.22.
  • The distillate that becomes whiskey must derive from 100% grain distilled at less than 190 proof.  Other restrictions apply to different types of the class whiskey.  I will talk only about the class standard.  Further,  I will ignore the corn whiskey exception.  All references here to "whiskey"  should be read as "whiskey except for corn whiskey."  
  • A distillate of 100% grain  distilled at less than 190 proof is not whiskey. 
  •  Such distillates becomes whiskey only after storage in an "oak container." 
  • The oak container necessary for turning an appropriate distillate into whiskey may be new or used.  The type of storage determines, in part,  the type of whiskey.
  • You can put oak staves in a barrel, but unless the barrel is oak, the spirit is not aged because it is not stored in oak.  That is a matter of definition.
  • Puting spirits into a container, of any type, that has oak staves, chips etc, is a treatment of the whiskey.   
  • If you treat the whiskey with oak staves, chips, etc  you must disclose that you treated it with staves, chips, etc.
  • The label for any whiskey that has not been stored in oak for four years or more must contain a statement of age.
  • If a whiskey is held in an oak for 5 seconds, then, if the  container is new, the statement would be "aged 5 seconds," or" aged not less than 5 seconds."
  • If the container is used, the statement of age will be "stored 5 seconds," or "stored not less than 5 seconds."
  • If a product does not meet a standard set out in §5.22, it must be labeled as a distilled spirits specialty. 
  • A distilled spirits specialty is supposed to be labeled "in accordance §5.35.
  • §5.35 requires a fanciful name and truthful and adequate statement of composition.  Other restrictions and conditions may apply.  For example:.
  • You may not state age on a distilled spirits specialty.
  • Unless a specialty item contains a class or type of spirit as an ingredient, the label may not make mention of the class and type.
  • Since a distillate of 100% grain distilled at less than 190 proof that has not been stored in oak is not a whiskey, it follows that the term whiskey could not appear on the label in the form "unaged whiskey" or"white whiskey" or any other reference that includes the term "whiskey".
  • An aside - Note that the unadorned class and type statement is deemed to be a truthful and adequate statement of composition when the product meets the standard for that type. 
  • TTB does not state it that way, but it is one way of thinking about the standards. 
  • Of course, the adequacy depends on how well the type standard is known.  Who among you would care to compare and contract blended whiskey, a blend of straight whiskeys,  and light whiskey.  I will not do it without rereading the standards, which few people routinely carry with them when they are shopping.

So, every label that was approved for white or unaged whiskey in the past was approved in error.  Don' try to confuse me with the fact that there are a few of them out there.  I know that.  So does TTB.

TTB recognizes that its position on age is  ludicrous, given its adamant refusal to require some minimal period of storage. 

Because it is ludicrous - or perhaps to remedy its past errors of approval - TTB  proposes to change the rules to create a standard for unaged or white whiskey.

Now, TTB does not use the word "ludicrous,"   That word is mine and I will own it.  Here, in TTB's won words, is how it describes the situation and a proposed change that would create a standard of identity for white and unaged whiskey.  I've taken the liberty of parsing the statement, bullet style, to make it easier to understand:

  • TTB also proposes to provide for a new type designation of ‘‘white whisky or unaged whisky.’’
  • TTB has seen a marked increase in the number of products on the market that are distilled from grain but are unaged or that are aged for very short periods of time.
  • Under current regulations, unaged products would not be eligible for a whisky designation (other than corn whisky) and would have to be labeled with a distinctive or fanciful name, along with a statement of composition. In order to provide guidance for these products.
  • TTB proposes that products that are either unaged (so they are colorless) or aged and then filtered to remove color should be designated as ‘‘white whisky’’ or ‘‘unaged whisky,’’ respectively.
  • This proposal represents a change in policy, because currently all whiskies (except corn whisky) must be aged, although there is no minimum time requirement for such aging.
  • TTB believes that currently some distillers may be using a barrel for a very short aging process solely for the purpose of meeting the requirement to age for a minimal time.
  • Consequently, TTB is proposing the new type designation of ‘‘white whisky or unaged whisky’’ and specifically requests comments on this new type and its standards.

I will add that TTB damn well knows that some distillers are using a very short aging process, which make a mockery of TTB's dual positions that  (1) age is important to creating the character a spirit must have to be whiskey, but (2) there is no need for a required minimum period of storage that will create the required character.  See - the term "ludicrous" does not seem to be so harsh a judgement after all.

If you have a horse in this race, comment,m as TTB that requests you to do.  Read the NPR at https://www.govinfo.gov/content/pkg/FR-2018-11-26/pdf/2018-24446.pdf and submit your comments through this link:  www.regulations.gov/comment?D=TTB-2018-0007-0001.

I emphasis that because it is important.  I provide the rather detailed background so that you know the context in which the proposal resides.

 

 

 

 

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Thanks @dhdunbar 

I submitted my comment to the TTB. The proposed changes are on pages 60593-60599 if anyone is interested, and reading just that isn't too terribly painful. Don't be put off by the shear volume of bureaucratic and legalistic excrement. These are also the changes that are considering defining a barrel as 50 gallons, which I know will hurt a lot of people, and have been discussed here. I've put off submitting a comment far too long. Not sure what the deadline is.

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Take an old 53 gallon barrel and steam all the tannin out of it until it is inert. 

 

Ferment your whiskey using something that is not a traditional whiskey yeast

 

Rest your white whiskey for six months in the inert barrel to blow off the heads

 

Boom you have made a wonderful product that consumers would have a more enjoyable experience drinking rather than a money grab to shove in a bottle ASAP

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