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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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