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Calculating PPM of licorice root in gin formula?

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I just submitted my first gin formula to the feds and this is what they sent back for correction:

 

Licorice Root is a limited ingredient, state the concentration in the method of manufacture in ppm.

 

Anyone know how I would go about determining PPM of licorice root?  I add around 24 grams per gal of spirit in a suspended bag in the still with all my other herbs.

Any help would be greatly appreciated.

Chris

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On 6/4/2018 at 12:54 PM, Dry Point Distillers said:

I just submitted my first gin formula to the feds and this is what they sent back for correction:

 

Licorice Root is a limited ingredient, state the concentration in the method of manufacture in ppm.

 

Anyone know how I would go about determining PPM of licorice root?  I add around 24 grams per gal of spirit in a suspended bag in the still with all my other herbs.

Any help would be greatly appreciated.

Chris

That is an odd reply from them. Usually, if they have a question along those lines, they will simply require a lab sample.

PPM of licorice root doesn't matter per se, it is the PPM of the limited chemical Glycyrrhizin. As Glycyrrhizin, it is limited to 0.1%, or 1000 PPM. Usually, if you indicate a limited amount of licorice added to the spirit in the process, it guarantees that you can not reach that limit. Likely your formula is in the gray area where the upper bound of your formula would not keep you below 0.1%? Because 1 gallon of spirit is 2987 grams, and if all 24 grams licorice was introduced into the spirit as Glycyrrhizin, then you would be 0.8%, which is well above the 0.1% limit. So, they need some way for you to demonstrate how you will ensure less than 0.1% using the quantities and method you describe. One way is if you knew the weight of the licorice before and after distillation, worse case assume all that is Glycyrrhizin, and calculate result of upper bound. It should be below 0.1%, IMO. Or offer to have them test it, they don't charge you.

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On 6/4/2018 at 1:54 PM, Dry Point Distillers said:

Licorice Root is a limited ingredient, state the concentration in the method of manufacture in ppm.

This is extremely odd... moreso since we got that exact verbatim request and our FOLA submission doesn't have licorice root in it...

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Yeah, it get weirder.  I Sent them a response stating that I don't have the means of testing a sample to determine the PPM of licorice root and requested that I send them a sample for their determination.  This is what I got back:

It is not a question of testing the levels, but you calculating the level and stating it. 

Final request

 

Not really sure what to do here...

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6 hours ago, Dry Point Distillers said:

Yeah, it get weirder.  I Sent them a response stating that I don't have the means of testing a sample to determine the PPM of licorice root and requested that I send them a sample for their determination.  This is what I got back:

It is not a question of testing the levels, but you calculating the level and stating it. 

Final request

 

Not really sure what to do here...

If you look at my response to you, that is what I suggested they are asking: you make an estimate, based on your method and quantities, on an upper limit for concentration. And I think they are trying to give you an opportunity to avoid testing, because from what you described, my rough estimate suggested that you could NOT estimate an upper limit that was within the legal limit. So, modify your formula or do a better estimation than I did so that you can meet the limit. But yes, what is odd is that they don't just test it, as they would for thujone level in absinthe. ON THE OTHER HAND, for absinthe you still have to have a formula that would result in an upper limit for the limited substance that is below the legal limit. And, for absinthe, there is no choice, a lab sample is required.

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This is what ended up being what they needed to pass my formula for Gin.  Thanks for your help in getting me here...

 

Licorice root is macerated in corn spirit and 24 grams of hydrated licorice root is added to the botanical basket. After distillation, licorice root is weighed and 23.5 grams of licorice root remain. .5 grams of licorice root is consumed, leaving .01% licorice root in product, 100PPM licorice root.

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4 hours ago, Dry Point Distillers said:

This is what ended up being what they needed to pass my formula for Gin.  Thanks for your help in getting me here...

You are welcome!

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Funny, the TTB made us send off our gin (which includes licorice in it's botanical bill) off to a lab for Glycyrrhizin testing, which is what they really care about in the end. The sample was way below their allowable limits, but it was still an unexpected pain, expense, and delay since they didn't have any issue with the licorice the first time the recipe was submitted with identical licorice quantities.

The best deal I found for Glycyrrhizin testing was at Covance Labs, but it was still $250 I wasn't planning to spend. 

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