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GNS Cost and Availability

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22 minutes ago, bluestar said:

See my most recent post.

Saw it. Thanks!

 

 

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On 8/13/2018 at 1:44 PM, bluestar said:

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.

Thank you very much, that did help make things a little clearer. I understand it this way now: All vodka is Neutral Spirits, but not all Neutral Spirits is vodka. So even though some of these suppliers make their juice to vodka standards, they for some reason label it as NGS and normally that would require a formula because you are changing class/type.

But that begged the question, why does the TTB not require a formula if you make it from scratch (where I know a lot of people are producing a NGS intermediate, just not classifying it at production I guess?) but require a formula if you cut that first part out? So I did some more investigative digging and eventually remembered a previous reply by @Jedd Haas mentioning the "general-use formulas"  https://ttb.gov/rulings/2016-3.pdf. It took a bit to wrap my head around it but what I gathered is, as long as you're making a spirit that fits the S.O.I. of vodka, you don't need a formula.

"TTB approves a general-use formula under §§ 5.26 and 19.348 for vodka produced in accordance with the standards of identity set forth in § 5.22(a)(1) and containing no harmless coloring, flavoring or blending materials other than sugar in an amount not to exceed 2 grams per liter, citric acid in an amount not to exceed 1 gram per liter, or both."

In fact, there is not an option to submit a formula for vodka.

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18 hours ago, JailBreak said:

Thank you very much, that did help make things a little clearer. I understand it this way now: All vodka is Neutral Spirits, but not all Neutral Spirits is vodka. So even though some of these suppliers make their juice to vodka standards, they for some reason label it as NGS and normally that would require a formula because you are changing class/type.

But that begged the question, why does the TTB not require a formula if you make it from scratch (where I know a lot of people are producing a NGS intermediate, just not classifying it at production I guess?) but require a formula if you cut that first part out? So I did some more investigative digging and eventually remembered a previous reply by @Jedd Haas mentioning the "general-use formulas"  https://ttb.gov/rulings/2016-3.pdf. It took a bit to wrap my head around it but what I gathered is, as long as you're making a spirit that fits the S.O.I. of vodka, you don't need a formula.

"TTB approves a general-use formula under §§ 5.26 and 19.348 for vodka produced in accordance with the standards of identity set forth in § 5.22(a)(1) and containing no harmless coloring, flavoring or blending materials other than sugar in an amount not to exceed 2 grams per liter, citric acid in an amount not to exceed 1 gram per liter, or both."

In fact, there is not an option to submit a formula for vodka.

You answered your own question at the very end: if you produce to the standards, then what is in the CFR constitutes the formula. The TTB does that for many spirits with clear standards of identity, and then rely on the COLA that you submit to not only be "legal" but truthful. For example, if you put on the Vodka label "distilled from grain", a required part of the label to indicate what the product is distilled from, they don't require a formula to check against, they require you to distill it from grain. They do the same for whiskies: if you are Rye Whiskey, you don't need a formula, but you must be 51%+ of rye in the mash; if you don't have an age statement, you don't need a formula, but you do need to be aged at least 4 years in new charred oak barrels, because the standards say so. It seems strange but makes sense: all you are sending them one way or the other is a filled out form (for formula and COLA), the combination of what you put on the forms with the rules in the CFR require you to make the product you eventually make and label to be made a certain way. By submitting the COLA (and possibly formula), and using the subsequent label on the product, YOU ARE LEGALLY BOUND AND ARE AVOWING TO MAKE THE PRODUCT AS LEGALLY DESCRIBED BY COLA (AND FORMULA) and relevant sections of the CFR! Strange how many distillers don't understand this, even some of the established craft distilleries. I have heard a distiller saying it was okay to use a label with no age statement, because the TTB eventually told them to remove the age statement (in this case, because they kept trying to use a legally unacceptable wording of the age statement), even though the whiskey was less than 4 years old. Give me a break! So, same for vodka: the standard says you will distill above 190 proof and if necessary charcoal filter to eliminate any distinctive flavor for the source. So you are legally obligated to do that. 

By the way, the text cited is specific to eliminating the need when harmless additives are employed, it was always so for general standards of identity.

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@bluestar Thank you kindly for your time and expertise as well as humoring my many hypothetical questions and questions in general. I have thoroughly enjoyed my learning experience here. :)

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I am late to this entertaining party.

Read this...

Quote

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.

Just got a COLA approval for my vodka which is 75% sourced GNS, 25% home-made GNS blended and re-distilled.  No formula required.  Just the commodity statement "Distilled 100% from Grains."

Doing the same base for our gin.

I am making healthy cuts in the final run.  GNS is inexpensive, so don't mind sending some down to clean the drains a bit.  Also proofing with my unique water design.

Allows me to keep the "local ingredients" bit and also tweak the product to that craft vodka profile with a slightly unique mouthfeel and finish.

In my opinion, GNS is not a craft-killing devil as long as there is honesty in the branding/labeling.   I see it as an ingredient commodity.  There is really not much art/craft required to produce it.  In my view the craft part is doing something with it that is crafty.  Those vodka purists that like their familiar near-tasteless ethanol experience have a lot of options I would prefer not to compete with.  Your local customers will let you know if you are creating anything good enough to sell and drink. 

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14 hours ago, Patio29Dadio said:

I am late to this entertaining party.

Read this...

Just got a COLA approval for my vodka which is 75% sourced GNS, 25% home-made GNS blended and re-distilled.  No formula required.  Just the commodity statement "Distilled 100% from Grains."

Doing the same base for our gin.

I am making healthy cuts in the final run.  GNS is inexpensive, so don't mind sending some down to clean the drains a bit.  Also proofing with my unique water design.

Allows me to keep the "local ingredients" bit and also tweak the product to that craft vodka profile with a slightly unique mouthfeel and finish.

In my opinion, GNS is not a craft-killing devil as long as there is honesty in the branding/labeling.   I see it as an ingredient commodity.  There is really not much art/craft required to produce it.  In my view the craft part is doing something with it that is crafty.  Those vodka purists that like their familiar near-tasteless ethanol experience have a lot of options I would prefer not to compete with.  Your local customers will let you know if you are creating anything good enough to sell and drink. 

Can't help but ask: how did you get a COLA  approved that says "Distiled 100% from Grains" when you clearly acknowledge that your "Craft Vodka" is actually 75% source NGS ?  

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19 hours ago, Patio29Dadio said:

I am late to this entertaining party.

Read this...

Just got a COLA approval for my vodka which is 75% sourced GNS, 25% home-made GNS blended and re-distilled.  No formula required.  Just the commodity statement "Distilled 100% from Grains."

Doing the same base for our gin.

I am making healthy cuts in the final run.  GNS is inexpensive, so don't mind sending some down to clean the drains a bit.  Also proofing with my unique water design.

Allows me to keep the "local ingredients" bit and also tweak the product to that craft vodka profile with a slightly unique mouthfeel and finish.

In my opinion, GNS is not a craft-killing devil as long as there is honesty in the branding/labeling.   I see it as an ingredient commodity.  There is really not much art/craft required to produce it.  In my view the craft part is doing something with it that is crafty.  Those vodka purists that like their familiar near-tasteless ethanol experience have a lot of options I would prefer not to compete with.  Your local customers will let you know if you are creating anything good enough to sell and drink. 

Re-read the thread. Sorry, technically, if you do that, you are breaking the law. Sure, you can get a COLA approved, but the COLA approved without a formula means you are approved for making vodka according to general standards, which means you are starting from something that is not yet classified as a spirit, and then distilling it to become vodka. If you take a spirit not classified vodka and do something to it to make it vodka, you changed classification, and by law (CFR) you are required to have a formula. The COLA approvers don't necessarily know that unless you happen to put something on the label that says explicitly that you are making the product that way. I am guessing your COLA was approved because nowhere on the label does it say it is made from previously produced GNS, does it? And, if you have a formula, it will tell them you are making from GNS. By the way, that formula MUST say the GNS is itself made from 100% grain, if you are going to say the final product is from 100% grain.

So, this is another illustration of the point I made previously in the thread: that people who get a COLA approved that is not suitable for the product they are making often assume it can used for that product. No. You are obligated by law to make sure the product labeled as per the COLA meets the requirements of that label. Without a formula, the approval of the COLA is only saying that such a label is legal for a product that fits the label as prepared. Without a formula, how can the TTB know if what you are going to put into the bottle fits the label requirements? They can't.

Also gin, if made from GNS, requires a formula for the same reason. And again, the COLA will be approved without it, if nothing on the label indicates the gin was not produced directly from fermentable.

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4 hours ago, Roger said:

Can't help but ask: how did you get a COLA  approved that says "Distiled 100% from Grains" when you clearly acknowledge that your "Craft Vodka" is actually 75% source NGS ?  

It was approved because he did not submit a formula saying he used GNS. If he had, he could still get an approval for that statement, I believe, if he specifies that the GNS is itself distilled from 100% grains.

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 If he had, he could still get an approval for that statement, I believe, if he specifies that the GNS is itself distilled from 100% grains.

He can not get a legal approval for an NGS based vodka/gin unless he declares on the label some derivation of "contains __% Neutral Grain Spirits for the segment of NGS therein.  Period.

No nuance, no special process, no special sauce will change the requirement.

The number one craft in our industry seems to be crafty labeling. 

 

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Interesting.  Good stuff.  I'm not trying to be "crafty" in labeling to do something I am not supposed to.  Reading the regs, without getting into a long winded debate, there seems to be plenty of gray area on NGS being re-distilled to vodka.  There are always going to be differences of opinion, but I have always taken the approach with respect to the regulations that the regulator is the decider.  As we often don't know the basis for the rules and risk going overboard in compliance.  In other words, I don't see any benefit in producers in the craft spirits industry becoming rule interpreters... we should just ask the officials for clarification and accept their ruling, but when there is undefined ambiguity I think it is an "American?" responsibility to assume the most beneficial alternative is allowed. 

My back label says "... is made from a blend of house-made spirit and sourced neutral spirits that are redistilled to capture a balanced profile".  There is a separate commodity statement that says "distilled 100% from grains"

And there isn't anything false or misleading about this labeling.  And frankly, in the scheme of things, I cannot wrap my head around any benefit to the consumer disallowing NGS to be redistilled to vodka.  Just ask Tito!

But if TTB missed something here, and there is a need for a formula... a formula will happen. 

Oh... and my gin has a formula.   Note that on the table of product categories from TTB and on the COLA online site, there is not a place to connect a formula to vodka... at least that I can find.

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15 hours ago, Patio29Dadio said:

Interesting.  Good stuff.  I'm not trying to be "crafty" in labeling to do something I am not supposed to.  Reading the regs, without getting into a long winded debate, there seems to be plenty of gray area on NGS being re-distilled to vodka.  There are always going to be differences of opinion, but I have always taken the approach with respect to the regulations that the regulator is the decider.  As we often don't know the basis for the rules and risk going overboard in compliance.  In other words, I don't see any benefit in producers in the craft spirits industry becoming rule interpreters... we should just ask the officials for clarification and accept their ruling, but when there is undefined ambiguity I think it is an "American?" responsibility to assume the most beneficial alternative is allowed. 

My back label says "... is made from a blend of house-made spirit and sourced neutral spirits that are redistilled to capture a balanced profile".  There is a separate commodity statement that says "distilled 100% from grains"

And there isn't anything false or misleading about this labeling.  And frankly, in the scheme of things, I cannot wrap my head around any benefit to the consumer disallowing NGS to be redistilled to vodka.  Just ask Tito!

But if TTB missed something here, and there is a need for a formula... a formula will happen. 

Oh... and my gin has a formula.   Note that on the table of product categories from TTB and on the COLA online site, there is not a place to connect a formula to vodka... at least that I can find.

Yes, I might have to disagree with @Roger about the commodity statement if using GNS as a source, that in fact if you redistill it, and you can verify that the source GNS is from a specific material, the vodka can be label as distilled from that material. But you have to be able to verify that with documentation and describe that in your formula.

I know I have a formula for my vodka, since it is made from re-distillation of whiskey feints (my own). Since whiskey feints are originally being classified as whiskey, the re-distillation causes a change in classification, and a formula is required. That formula has a label approved saying it is "distilled from grain", and my formula makes clear that the feints are distilled from grain, then redistilled. I tried to get the label to include "distilled from whiskey feints", but the TTB would not allow that, indicating the vodka commodity statement should identify the origin material for fermentation.

Usually, if your labeling indicates that your method of production requires a formula, the COLA folks will catch that, and not approve the label, pointing out that you need a formula. But keep in mind, there are many COLA approved or not approved erroneously by TTB these days, often from less experienced officers or temporary assignments from wine to spirit. At least, that has been my experience. But if a COLA gets approved by mistake, they can, at any time, correct that and ask you to correct your labeling. They are not liable for their error, you are liable to meet the law, in any case.

Regarding Tito's, I note that it is "distilled from 100% corn", but also note that it does not have a formula identified. On the other hand, they supposedly purchase the product in bulk, and complete distillation on site. It would be good to confirm this, but this could be possible, and legal, if what they purchase is classified as vodka to begin with, then no formula would be required. That means you could do the same thing, if your GNS manufacturer was willing to classify the product when produced as vodka when they sell it to you, then you would be able to redistill it and it would be still vodka.

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But keep in mind, there are many COLA approved or not approved erroneously by TTB these days, often from less experienced officers or temporary assignments from wine to spirit. At least, that has been my experience. But if a COLA gets approved by mistake, they can, at any time, correct that and ask you to correct your labeling. They are not liable for their error, you are liable to meet the law, in any case.

Thanks for the feedback.  Great stuff!

I am going to look into this and talk to my alcohol industry attorney.  If you think about the ramifications of this for a big producer getting a mistake from a TTB regulator... it could cost millions.  I can accept it when the determination is clear, but there are a lot of gray areas in the regulations.  Otherwise why do labels need to be approved by TTB?.. just publish the regs and require all the producers to follow the rules or risk getting a cease and desist when they get it wrong!  I think the reason is clear... the labeling regulations are complicated and subject to different interpretation.   Sometimes the prize goes to those that push the ambiguity and get an approval instead of assuming something is disallowed. 

Question about NGS or GNS (hear it both ways)... when would it NOT be distilled from grain?

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9 hours ago, Patio29Dadio said:

when would it NOT be distilled from grain?

Primarily grape but also molasses distilled to > 190.

 

 

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2 hours ago, indyspirits said:

Primarily grape but also molasses distilled to > 190.

 

 

Also cane neutral is pretty big. Guessing similar to molasses but cleaner.

 

On 8/18/2018 at 8:11 PM, Patio29Dadio said:

Oh... and my gin has a formula.   Note that on the table of product categories from TTB and on the COLA online site, there is not a place to connect a formula to vodka... at least that I can find.

This was the last bit of my argument earlier if you had noticed. I am siding with you on this one and it is my opinion as long as you are producing in accordance with the S.O.I. you don't need a formula. Otherwise it is just semantics because I know a lot of people produce a NGS as an intermediate in their vodka production. There is no difference in my eyes between that and sourcing it besides "naming" one of them vodka as it came off the still (though it hasn't matched the S.O.I. of vodka yet..). 

I may be 100% wrong but at least my way of thinking makes sense and cuts back on wasted time and money. I do believe people should be 100% transparent with their methods like you are doing @Patio29Dadio.

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Primarily grape but also molasses distilled to > 190.

Interesting.  I always assumed that the "G" in "NGS" or "GNS" referred to "grain" and that it meant that the spirit was produced using 100% grain.  Maybe I have this wrong and NGS or GNS can be made from may things, and thus it is up to me to make sure that the sourced spirit I use is 100% distilled from grain.

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You are correct that the 'G' stands for grain. If made with something else (must, cane, etc.) they are merely neutral spirits. 

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