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Onerous state laws basically prevented small distillers from operating. Grow up. 

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15 hours ago, Silk City Distillers said:

Did a double blind tasting of vodkas with 20-30 other distillers.  Smirnoff won.  Plastic bottle Popov commanded a very respectable position, I believe Svedka did as well.  I won’t say what the craft distillers ranked as the worst vodkas.

Smirnoff is grain to glass and thats the same Moto most "craft" distillery hang their hats on.   Sure they are way bigger but they are doing the same thing lots of small craft brands do only better.   Iv tastes plenty of vodka made from small craft brands that taste like dank ass.  Just because your big and selling at a value doesn't mean your not good at your craft. 

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15 hours ago, Silk City Distillers said:

Did a double blind tasting of vodkas with 20-30 other distillers.  Smirnoff won.  Plastic bottle Popov commanded a very respectable position, I believe Svedka did as well.  I won’t say what the craft distillers ranked as the worst vodkas.

Smirnoff is grain to glass and thats the same Moto most "craft" distillery hang their hats on.   Sure they are way bigger but they are doing the same thing lots of small craft brands do only better.   Iv tastes plenty of vodka made from small craft brands that taste like dank ass.  Just because your big and selling at a value doesn't mean your not good at your craft. 

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9 hours ago, Roger said:

Onerous state laws basically prevented small distillers from operating.

Reference? 

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6 hours ago, whiskeytango said:

Iv tastes plenty of vodka made from small craft brands that taste like dank ass.

Couldn't have put it better!  

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4 hours ago, indyspirits said:

Reference? 

Come now, that is a bit snarky. Everyone in the industry knows it is so: in the 2000's many states added special craft distillers licenses that made it feasible, both economically and in terms of business plans, to start a small distillery. Geez, you are in IN, and you should know that is true for your state, where there was an existing large and small(er) distillery, but those couple were locked in place, and no others allowed! In our states, IL and MI, prior to craft licenses, there either was a very expensive license with no on-site retail sales capability (IL) or no license whatsoever (MI). And in addition to the limitation at the state level for the majority of states, most localities were not willing to provide licenses either. Craft breweries helped pave the way in many states for local governments to consider licensing craft distilleries. Once these special craft licenses were put in effect in each state, those states saw significant and sometimes explosive growth in the number of craft distilleries. Reference? How about all the craft distilling press in the past 2 decades.

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4 hours ago, indyspirits said:

Couldn't have put it better!  

True, but some taste great. Well, I will speak for myself, mine tastes GREAT! In the end, I feel so long as you tell the consumer what they are buying, they can decide what to purchase. Unfortunately, the TTB rules do not require that a distillery indicate if they have actually distilled the product to the point of being vodka by virtue of plates of separation in the still: hence, you can buy something previously distilled over 190, and then run it through your still, filter, and say it is your distilled vodka. And thus, why there is some negative blow back on using GNS to make vodka and then say you distilled it. I would not have a problem if the TTB required that you could not use the "distilled by" approbation unless your still causes it to change from GNS to vodka by virtue of distilling over 190 proof and filtering. In fact, in one conversation (but not others) I had with the TTB formula folks, I was told that you would have to indicate in your formula that you are distilling to over 190 proof and filtering to use the "distilled by" on the label, as opposed to the "produced by". But if that were so, the TTB COLA folks would have to catch that, when checking the formula. Problem is, you can get a vodka label approved without a formula. BUT, if you are buying GNS (not officially sold as vodka) and redistilling to call it vodka, in fact, you need a formula, because you are changing the classification of the spirit. Many don't realize this.

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34 minutes ago, bluestar said:

Geez, you are in IN, and you should know that is true for your state, where there was an existing large and small(er) distillery, but those couple were locked in place, and no others allowed!

That's not exactly accurate. There was no limitation on new distilleries in Indiana.  Prior to the Artisan law the state license was $2,500 and there was no provision for on-premise sales. Notwithstanding, there were about a half-dozen distilleries (including LDI) some of which were only rectifiers (See Indiana Bourbon / Harrison Bourbon). In short there was no law preventing distillery start-ups, but on the flip-side there were no incentives to start one.  The vast majority of new distilleries that opened after Jan 1 2015 still don't fall under the artisan law (you must have been in operation for 24 months) so they are operating under the same regs as if they opened in the mid 1990s.

 

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39 minutes ago, bluestar said:

Reference? How about all the craft distilling press in the past 2 decades.

Again, the OP said there were laws preventing craft distillers. There were not (at least in Indiana).

 

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31 minutes ago, bluestar said:

BUT, if you are buying GNS (not officially sold as vodka) and redistilling to call it vodka, in fact, you need a formula, because you are changing the classification of the spirit. Many don't realize this.

You've piqued my curiosity. The class "Neutral Spirits" is broadly defined as:

Quote

Spirits distilled from any material at or above 95% alcohol by volume (190 proof), and if bottled, bottled at not less than 40% alcohol by volume (80 proof)

And vodka is:

Quote

Neutral spirits distilled or treated after distillation with charcoal or other materials so as to be without distinctive character, aroma, taste or color

If a rectifier charges the still at say... 50% ABV and redistills to 95% how are they changing the classification? Is it the act of dilution? What if they simple reduce to 50% and filter without re-rectifying? Clearly this is now getting a bit far afield from the OP but I feel closely enough related so I shouldnt be labels a thread hijacker (although apologies to the OP regardless).  

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14 hours ago, Roger said:

Onerous state laws basically prevented small distillers from operating. Grow up. 

I agree,  The laws in MO changed in 2009 to make starting a distillery in MO a much easier process.  It's common knowledge that many other states have done the same.

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The entire topic of how changes in state laws over the past 10 years have allowed for the expansion of craft distillers is to absurd to even comment on. Move along Indy, you are usually less obtuse. 

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1 hour ago, Roger said:

Move along Indy, you are usually less obtuse. 

Fair enough. Moving along.

 

 

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4 hours ago, Southernhighlander said:

The laws in MO changed in 2009 to make starting a distillery in MO a much easier process.

Off topic: Am I correct in my understanding that home distilling is legal in MO?

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Yes, home distilling has been legal in MO since 2009, and our state law enforcement, including the state ATC, enforce state law, which states that an individual may produce up to 100 gallons  per year for himself or up to 200 gallons per year for himself and his family, however home distilling is illegal under federal law.  I follow federal law but I am hoping that home distilling will be made legal under federal law, like beer and wine making was in the 1970s.  It is certainly no more dangerous than using a propane fired fish fryer or turkey fryer and a lot more people have died from pressure canners blowing up than stills. 

MO is a great deal less intrusive than most states.  You know, less of a nanny state.  It is one of the few states where there is no law against public drunkenness.  You can carry concealed without a permit.  There are no state laws requiring building permits or building inspections.  Of course most MO municipalities  have laws concerning building permits and inspections etc.  MO is one of the best states to start a distillery.  You can sell by the drink and by the bottle right out of your distillery and there is no limit.

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22 hours ago, indyspirits said:

If a rectifier charges the still at say... 50% ABV and redistills to 95% how are they changing the classification? Is it the act of dilution? What if they simple reduce to 50% and filter without re-rectifying? Clearly this is now getting a bit far afield from the OP but I feel closely enough related so I shouldnt be labels a thread hijacker (although apologies to the OP regardless).  

This thread has derailed from the OP a long time ago. 

That being said, I'm also curious about this because I have seen a few times you need formula approval for vodka made from sourced NGS. I've also heard that you need to redistill or treat NGS with charcoal or some other material to change it to vodka. However, the way I look at it the TTB states NGS is a class and vodka is a specific type of NGS that is:

Neutral spirits distilled or treated after distillation with charcoal or other materials so as to be without distinctive character, aroma, taste or color.

So could you not just dilute to target proof and argue that the NGS you sourced was distilled so as to be without distinctive aroma, color, etc.? Then you would just be designating your NGS as vodka rather than the other type, 'Grain Spirits'. You wouldn't be changing class or type so no formula would be needed. 

Another way I look at it is when you make whiskey. When it comes off the still it is the general class 'whiskey'. What you do with your distillate will dictate what type it falls under. Whether it be Straight Bourbon or mere corn whiskey. Neither of those require formula because you're not changing the class or type, merely designating it to a type. 

The two examples seem to be identical. If someone with much more knowledge can show me how I am wrong, in a way that is easy to understand, please do so because this is something I've struggled to wrap my head around. 

Side not: While I'm not a fan of NGS sourced vodka, I've been in operations that do it. I feel like redistilling it so you can put 'Distilled by:' on the bottle is more misleading than simple dilution and filtering with a subsequent statement of 'Produced by:'. I have more opinions on it and am open to further discussion.

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On 8/5/2018 at 11:33 AM, indyspirits said:

You've piqued my curiosity. The class "Neutral Spirits" is broadly defined as:

And vodka is:

If a rectifier charges the still at say... 50% ABV and redistills to 95% how are they changing the classification? Is it the act of dilution? What if they simple reduce to 50% and filter without re-rectifying? Clearly this is now getting a bit far afield from the OP but I feel closely enough related so I shouldnt be labels a thread hijacker (although apologies to the OP regardless).  

What you say is correct, except it matters how it was originally classified when originally made! Even if you made it to the specifications of vodka at the start, if you classified it as neutral spirits to begin with, to go to vodka is a reclassification and requires formula, because that is the rule: a formula is required whenever a spirit in one category is processed to classify it into another category.

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TTB made some changes to formula requirements in their 2016-3 circular, which can be downloaded here:

https://www.ttb.gov/formulation/do-I-need-a-formula.shtml

In short, TTB approved "general use formulas" for certain common types of spirits, including vodka. Meaning a formula is not needed. See the circular for the exact language; there was also a thread that touched on this when the ruling came out.

 

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1 hour ago, Jedd Haas said:

TTB made some changes to formula requirements in their 2016-3 circular, which can be downloaded here:

https://www.ttb.gov/formulation/do-I-need-a-formula.shtml

In short, TTB approved "general use formulas" for certain common types of spirits, including vodka. Meaning a formula is not needed. See the circular for the exact language; there was also a thread that touched on this when the ruling came out.

 

That was where I read that you need to 'do something' to NGS to turn it into vodka. I can slightly understand what Dunbar and Bluestar are both getting at for formula approval, it just doesn't make sense and seems convoluted to me. I also think you should still be able to argue that designating a type-less spirit (NGS is a class, not a type) to one of its types (Vodka) isn't changing its class (still under NGS) or type (it didn't have a type to start with). 

Here's the hypothetical I think of. I have just ran a distillation run producing near azeotrope. It was distilled to have no distinctive color, aroma, etc. This distillate fits the S.O.I. of two things. The class NGS and the sub-class (or type) Vodka. Whether I name it one or the other should not prevent me from considering the distillate as both. Same goes for if I sourced that NGS through another company. It's a waste of time and tax-payer dollars to have a TTB officer look at a formula approval for changing NGS (made to vodka specifications) to vodka IMO.

 

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According to the TTB, Vodka must "be without distinctive character, aroma, taste or color."  I have tried several craft vodka's made from scratch that do have flavor.  For example, I have tasted wheat vodkas in 3 different distilleries that had a vanilla taste and smell.  It was very light but easily detected.  I have had other vodkas that have detectable flavors.  If we follow the identity of Vodka laid down by the TTB those spirits are not really Vodkas, correct?

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1 minute ago, Southernhighlander said:

According to the TTB, Vodka must "be without distinctive character, aroma, taste or color."  I have tried several craft vodka's made from scratch that do have flavor.  For example, I have tasted wheat vodkas in 3 different distilleries that had a vanilla taste and smell.  It was very light but easily detected.  I have had other vodkas that have detectable flavors.  If we follow the identity of Vodka laid down by the TTB those spirits are not really Vodkas, correct?

Yes, but that is a subjective evaluation. NOTE: it does NOT say NO character, aroma, taste or color. It does not say "detectable". What does "distinctive" mean? It could mean, so as to distinguish one vodka from another. But clearly you can do that even with supposedly totally neutral products. So, yes, you could be found NOT to be a vodka by violating this, but since it is not quantitative, etc. On the other hand, being of 190 proof and some degree of filtration CLEARLY are requirements of vodka. And the change of type requires formula, regardless.

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3 hours ago, bluestar said:

Yes, but that is a subjective evaluation. NOTE: it does NOT say NO character, aroma, taste or color. It does not say "detectable". What does "distinctive" mean? It could mean, so as to distinguish one vodka from another. But clearly you can do that even with supposedly totally neutral products. So, yes, you could be found NOT to be a vodka by violating this, but since it is not quantitative, etc. On the other hand, being of 190 proof and some degree of filtration CLEARLY are requirements of vodka. And the change of type requires formula, regardless.

Except the TTB doesn't say filtration is a requirement. I don't mean to step on any toes and I have no doubt you know way more about regulations than me, but I have yet to see anywhere where the TTB requires filtration for it to be considered vodka. I vaguely understand the formula requirement, since you could argue you are changing it's classification from 'no type' to 'type: vodka' (as I understand it) but still don't see why it is needed if you are merely diluting.

Sorry for being a pain. I am still fairly green but have come to realize a lot of the TTB regulations are structured poorly (IMO). Thank you everyone for being patient in explaining the reasons behind some of them. I have another hypothetical but I think I'll make a new thread for that one. 

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On 8/9/2018 at 3:12 PM, JailBreak said:

Except the TTB doesn't say filtration is a requirement. I don't mean to step on any toes and I have no doubt you know way more about regulations than me, but I have yet to see anywhere where the TTB requires filtration for it to be considered vodka. I vaguely understand the formula requirement, since you could argue you are changing it's classification from 'no type' to 'type: vodka' (as I understand it) but still don't see why it is needed if you are merely diluting.

Sorry for being a pain. I am still fairly green but have come to realize a lot of the TTB regulations are structured poorly (IMO). Thank you everyone for being patient in explaining the reasons behind some of them. I have another hypothetical but I think I'll make a new thread for that one. 

Yeah, you are being a bit of a pain, but since others might share your confusion, allow me to spell it out and bludgeon you over the head with it a bit, okay?

Vodka does not "require" charcoal filtration, but such filtering is a means by which one can show you have met the requirements (from the CFR):

‘‘Vodka’’ is neutral spirits so distilled, or so treated after distillation with charcoal or other materials, as to be without distinctive character, aroma, taste, or color.

Yes, you can just distill to make vodka, by getting over 190 proof AND achieving lack of distinctive character, etc. But you can also buy GNS (over 190 proof) and charcoal filter to do the same. Some of us do both. I can tell you, for a fact, that charcoal filtering cleans up flavor and aroma, so it is any easy route to get there.

Here is why you must do SOMETHING to the GNS (other than just dilute it) and MUST submit a formula: since it was NOT classified as vodka, even if above 190 proof, then the TTB and you must ASSUME it did not fulfill the requirements for vodka, that otherwise are about standards of character, because IF it did, then it SHOULD have been classified as vodka. And now, if you are going to make said GNS that is NOT vodka into vodka, you must do something to it, and if you are not re-distilling it, adding water won't be enough to show that you have done something to modify it to guarantee it is without distinctive character, etc. And you need the formula, not only because you are changing category, but also to show what procedure you are doing to meet the requirement.

Sorry, no wiggle room: if you are purchasing GNS (not classified already as vodka) to make vodka, you need a formula submitted and approved, and something in that formula will show that you are doing something to the GNS so that it will meet the requirements for vodka.

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On 8/5/2018 at 11:33 AM, indyspirits said:

You've piqued my curiosity. The class "Neutral Spirits" is broadly defined as:

And vodka is:

If a rectifier charges the still at say... 50% ABV and redistills to 95% how are they changing the classification? Is it the act of dilution? What if they simple reduce to 50% and filter without re-rectifying? Clearly this is now getting a bit far afield from the OP but I feel closely enough related so I shouldnt be labels a thread hijacker (although apologies to the OP regardless).  

See my most recent post. There is both a procedural and legalistic reason for why something classified initially as Neutral spirits needs a formula to convert it to Vodka, and something must be done to it.

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