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Whiskey Hypothetical


JailBreak

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Hi all, 

Fairly green distiller here with an hypothetical that I thought of while trying to wrap my head around some of the TTBs regulations regarding formula requirements.

Say I develop a mash bill of 80% corn, 10% malted barley, and 10% rye. Say I distill in twice (not that important) and the proof at distillation is 150. What would I designate the distillate? Would I designate it as the general class 'whiskey'? Or would I designate it as corn whiskey since it fits the S.O.I.? 

Now follow close. Say I wanted to use that distillate both for a white corn whiskey as well as a bourbon. Could I use a singular batch for both? What then would I call the distillate? Would I need formula approval since I would have to designate it as one spirit (whiskey or corn whiskey) then change it's class/type to another (bourbon) even though bourbon does not require a formula approval normally? 

Now focusing on a singular barrel of that sweet, sweet bourbon. Say I partially-harvest an amount in 1 year for a small bottling. Would the aging clock stop even though the whiskey leftover never left the barrel? Or could I age it longer than 2 years and get the Straight Bourbon designation? If I am able to, how does that affect formula requirements? All three of those products normally don't require a formula and I'm in no way using weird techniques in production. Would I still need a formula approval for at least 2?

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From my understanding, you do not need a formula approval for anything you have proposed. Except the “White whiskey” which you probably wont get approved at all. You can call it “White Dog” or Moonshine, or premium dogshit. But unless you get lucky with a clueless TTB agent, the words White and Whiskey wont go next to each other on a label.

As it comes off the still it is not yet whiskey, it has to touch cooperage. If it goes into used, or uncharred new barrels, it is corn whiskey. If it goes into new American oak, it is bourbon. 

Good luck trying to get a “White Whiskey” COLA. 

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These were all really hypothetical questions regarding formula approval requirements. Also, corn whiskey doesn't have to touch cooperage at all or require a formula. There are several brands out there of a 'white' corn whiskey that state specifically that.

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Yeah I understand the distinction between the two. That wasn't really what my hypothetical was getting at. What it is getting at is, if I were to do a SINGLE 'batch' (mash, ferment, stripping run, finishing run) with that grain bill, I am able to make 3 products out of it that normally do not require formula approval. But what do I call the distillate fresh off the still? And would I need formula approval if I were to call it corn whiskey then put it into a barrel and call it bourbon, since I am changing class/type? Or what if I were to just call it the general class 'whiskey', would I need formula approval for all 3? 

One of the only questions not concerning formula requirements is, does the aging clock stop if you partial harvest a barrel even though the remaining whiskey never left the barrel? And one that came to mind just now, are there fill requirements on barrels? Wouldn't a half-filled barrel behave slightly different than a full one?

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I don't think you can do it all in one batch as that would be changing types which would require a formula.  You could do it with one mash bill and different runs, i.e. This one is corn whiskey, this one is bourbon.  A local distiller does that.  Same mash bill for two different products.  If you define it up front as a type and don't change it, no formula is required.  

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Am I the only one who has a problem with that? No part of the process changes and the S.O.I. are met either way. But the way it is, 3 separate but identical batches=no formula. One batch split into three products=2 to 3 formulas. The real kicker is, unless you disclose your entire process, no one would be able to tell the difference. 

What if you make a batch as corn whiskey then realize it is a little funkier than you wanted so you toss it in a barrel to become bourbon instead? Or the other way around, produce a batch of 'bourbon' but really enjoy the flavor as a new make?  Just seems like a waste of resources and a burden on the distiller to me.

Thanks for the input! Any answers to the barrel questions?

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Bourbon is best made from sour mash and is traditionally made from sour mash because of the flavor profile.  Corn whiskey is generally from sweet mash because is has a much better flavor profile right out of the still.  If done correctly sweet mash corn whiskey will have a nice buttery corn on the cob flavor.  Most people do not like sour mash as an unaged whiskey.  It is said that you cannot improve sweet mash corn whiskey by aging it in a charred barrel, because the sweet mash flavors do not work well in the barrel.  Using, sweet mash corn whiskey for bourbon is not a good idea in my opinion but it is just an opinion.

 

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@Southernhighlander Thanks for the information! I did not know that about the two types of mash. I knew what they were, just didn't know one may be better than the other for specific products. Like I said earlier, these are purely hypothetical questions to help me further understand some TTB regulations. I will definitely remember your advice if I ever produce a corn whiskey though! 

A little off topic but how would you produce that very first batch of sour mash?

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9 minutes ago, Oregon Spirit Distillers said:

Corn Whiskey has to be 100% corn.  

CFR 27, Chapter 1 Subchapter A Part 5 Subpart C 5.22 (ii) “Corn whisky” is whisky produced at not exceeding 160° proof from a fermented mash of not less than 80 percent corn grain, and if stored in oak containers stored at not more than 125° proof in used or uncharred new oak containers and not subjected in any manner to treatment with charred wood; and also includes mixtures of such whisky.

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Maybe I'm wrong, but I do what you are talking about.  I will aggregate whiskey from multiple runs into a tank, then barrel some as bourbon and bottle some as unaged corn whiskey.  Or sometimes if I am using a small barrel, will fill it with part of a run to make single batch bourbon and put the rest into the spirit tank for future bottling.

On the production report I put my monthly production into the appropriate type and class; but I don't see where in law it says you have to put all of a single run into one class and leave it there.  If at the end of the month I record having a bulk tank of unaged corn whiskey in storage, and then the next month I barrel half for bourbon and move the other half to processing for bottling as unaged corn whiskey, I would record that half has left storage and half remains in storage. There is no where on the storage report to record moving product already in storage into barrels.

I "think" as long as each months new months production and storage are recorded as the appropriate class they are in at the end of the month then regulations are satisfied?   

I would think if TTB where to question the authenticy of your bourbon as bourbon, your package records for the barrel and the corresponding mash record with mash bill would satisfy the requirements. 

I'm sure there is someone out there with more experience than me.

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On 8/10/2018 at 10:12 AM, Southernhighlander said:

Bourbon is best made from sour mash and is traditionally made from sour mash because of the flavor profile.  Corn whiskey is generally from sweet mash because is has a much better flavor profile right out of the still.  If done correctly sweet mash corn whiskey will have a nice buttery corn on the cob flavor.  Most people do not like sour mash as an unaged whiskey.  It is said that you cannot improve sweet mash corn whiskey by aging it in a charred barrel, because the sweet mash flavors do not work well in the barrel.  Using, sweet mash corn whiskey for bourbon is not a good idea in my opinion but it is just an opinion.

 

Sorry, I don't agree. In Kentucky and Tennessee, bourbon is traditionally (since early 19th C) made from sour mash. Sweet mash bourbon was made BEFORE sour mashing (so it is the earliest style), and continued to be in many states where there was access to more neutral (less alkaline) water. And sweet mash actually makes GREAT bourbon, but it is different. Sour mashing originally was not done because of flavor per se, it was done as a cheap quality control method to correct pH from overly alkaline water generated from limestone springs, which had a tendency to spoil sweet-mash beers.

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On 8/10/2018 at 12:49 PM, Silk City Distillers said:

You could sour with bacteria - typically lactobacillus.

Sorry, that is "old fashioned" sour mashing, not "sour mash" whiskey, as practiced in Kentucky and Tennessee. In fact, typically it is done on a sweet mash.

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22 hours ago, Still_Holler said:

Maybe I'm wrong, but I do what you are talking about.  I will aggregate whiskey from multiple runs into a tank, then barrel some as bourbon and bottle some as unaged corn whiskey.  Or sometimes if I am using a small barrel, will fill it with part of a run to make single batch bourbon and put the rest into the spirit tank for future bottling.

On the production report I put my monthly production into the appropriate type and class; but I don't see where in law it says you have to put all of a single run into one class and leave it there.  If at the end of the month I record having a bulk tank of unaged corn whiskey in storage, and then the next month I barrel half for bourbon and move the other half to processing for bottling as unaged corn whiskey, I would record that half has left storage and half remains in storage. There is no where on the storage report to record moving product already in storage into barrels.

I "think" as long as each months new months production and storage are recorded as the appropriate class they are in at the end of the month then regulations are satisfied?   

I would think if TTB where to question the authenticy of your bourbon as bourbon, your package records for the barrel and the corresponding mash record with mash bill would satisfy the requirements. 

I'm sure there is someone out there with more experience than me.

Yeah, this is a little tricky. At one point we had to discuss this in detail with a TTB officer. Because we do the same thing: we make a new-make corn-based (80%+) spirit (under 160 proof) that later in the production will be either not aged, aged in new charred oak, aged in used charred oak, or even redistilled again. If you need to record it in storage on a monthly BEFORE it is decided how then storage will be done, then technically it is unaged corn whiskey. Bourbon has to be stored in oak until aging is done. But if you keep it in production, in a tank, that can be treated as a bourbon or corn whiskey designate, which means it is not yet typed or classified, but intended for that use. Since it is not typed until stored, you don't have to submit a formula. But technically, if you stored it as a specific type, then changed your mind, you might have to use a formula.

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On 8/11/2018 at 2:06 PM, bluestar said:

Sorry, I don't agree. In Kentucky and Tennessee, bourbon is traditionally (since early 19th C) made from sour mash. Sweet mash bourbon was made BEFORE sour mashing (so it is the earliest style), and continued to be in many states where there was access to more neutral (less alkaline) water. And sweet mash actually makes GREAT bourbon, but it is different. Sour mashing originally was not done because of flavor per se, it was done as a cheap quality control method to correct pH from overly alkaline water generated from limestone springs, which had a tendency to spoil sweet-mash beers.

Bourbon made from sweet mash is different and I don't care for it. I really like Jim Beam single barrel, Booker's, Four Roses single barrel, Blanton's single barrel, Elijah Craig barrel select, Pappy Van Winkle's, Wild Turkey Decades and the good old stand byes like, Evan Williams and Heaven Hill.  Note that none of these are sweet mash bourbons.  In fact, I don't think that there has been s a sweet mash bourbon in the top 10 or maybe even the top 50 best selling Bourbons in the US, in modern times.

  I have never had a sweet mash bourbon  that I liked.  I have had a few sweet mash corn whiskeys that I loved.  I really like the buttery corn on the cob flavor of a good unaged sweet mash corn whiskey.   Sour mashing has been around for far longer than James Crow and it has been used extensively for almost 200 years and that's traditional enough for me.  Keep in mind that I'm a bourbon lover, Canadian blended whiskeys and light whiskeys are not my favorite, however I know some others love them, especially the Canadian blended whiskeys

Please read the below from bourbanbantor.com

" To this day, Crow is known as the father of modern bourbon, since nearly every widely available bourbon is produced via the sour mash process, even the ones that do not boast the fact on their labels. The very few sweet mash bourbons released in the last hundred years have been released as more of a novelty than anything else. "  

 

That being said, craft is all about doing different things, experimenting and pushing the limits to find something unique and wonderful.  I will try other sweet mash bourbons as I run across them and if i find one that I like i will let you know.

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6 hours ago, Southernhighlander said:

I really like the buttery corn on the cob flavor of a good unaged sweet mash corn whiskey.

The most interesting part of this hot buttered popcorn, corn-on-the-cob flavor, is that it actually has absolutely nothing to do with the corn.  It's diacetyl, a fermentation byproduct, while yeast an produce it, in a sweet mash, it's more likely going to come from lactobacillus and pediococcus.  This is further amplified by short fermentation timeframes.

While a lot of diacetyl is a fault (though maybe not in corn whiskey), a little bit can really emphasize flavors of butterscotch, toffee, caramel, butter, as well as enhance mouthfeel.

 

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13 hours ago, Silk City Distillers said:

The most interesting part of this hot buttered popcorn, corn-on-the-cob flavor, is that it actually has absolutely nothing to do with the corn.  It's diacetyl, a fermentation byproduct, while yeast an produce it, in a sweet mash, it's more likely going to come from lactobacillus and pediococcus.  This is further amplified by short fermentation timeframes.

While a lot of diacetyl is a fault (though maybe not in corn whiskey), a little bit can really emphasize flavors of butterscotch, toffee, caramel, butter, as well as enhance mouthfeel.

 

My grandfather made sweet mash corn whiskey using the method that you describe. I will probably also make a white rum using a similar method to get a butterscotch flavor.    

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23 hours ago, Southernhighlander said:

Bourbon made from sweet mash is different and I don't care for it. I really like Jim Beam single barrel, Booker's, Four Roses single barrel, Blanton's single barrel, Elijah Craig barrel select, Pappy Van Winkle's, Wild Turkey Decades and the good old stand byes like, Evan Williams and Heaven Hill.  Note that none of these are sweet mash bourbons.  In fact, I don't think that there has been s a sweet mash bourbon in the top 10 or maybe even the top 50 best selling Bourbons in the US, in modern times.

  I have never had a sweet mash bourbon  that I liked.  I have had a few sweet mash corn whiskeys that I loved.  I really like the buttery corn on the cob flavor of a good unaged sweet mash corn whiskey.   Sour mashing has been around for far longer than James Crow and it has been used extensively for almost 200 years and that's traditional enough for me.  Keep in mind that I'm a bourbon lover, Canadian blended whiskeys and light whiskeys are not my favorite, however I know some others love them, especially the Canadian blended whiskeys

Please read the below from bourbanbantor.com

" To this day, Crow is known as the father of modern bourbon, since nearly every widely available bourbon is produced via the sour mash process, even the ones that do not boast the fact on their labels. The very few sweet mash bourbons released in the last hundred years have been released as more of a novelty than anything else. "  

 

That being said, craft is all about doing different things, experimenting and pushing the limits to find something unique and wonderful.  I will try other sweet mash bourbons as I run across them and if i find one that I like i will let you know.

First, on taste, we will simply have to agree to disagree. Although I suspect you have not had that many sweet mash bourbons of quality. Since Kentucky dominated the industry after prohibition, and since it pretty much exclusively made sour mash, that is what has dominated the industry.

Sour mashing had been experimented with since the beginning of the 19th century, but was not standardized as a process until Crow in 1831. It gets quickly adopted throughout Kentucky and Tennessee, for the reasons I described. Also about this time the Coffey tower still is introduced, and is well adopted in Kentucky by the latter part of the 19th century, instead of pot stills. This is "modern" bourbon: sour mashed and distilled in a Coffey tower still. Since sour mashing is the earlier of the two modernizations, and introduced as a standard by Crow, hence why he is the father of "modern" bourbon. I prefer the "old-fashioned" stuff: sweet mash in a pot still. Of course I do, why else would I make it? Well also because, as you say, the point of a craft distillery should be to do things that a large distiller is unlikely to do, IMO.

By the way, you seem to imply that I implied that sour mash was not traditional. If you read what I wrote again, it agrees with what you said: it is traditional, made since the early 19th century, but the sweet mash is an earlier style, although not the current tradition, if you like. Not that sweet mash wasn't made in the 20th century. For example, while Ten High today, made in Kentucky by Barton, is a sour mash, originally, it was produced by Hiram Walker in Peoria, IL. It was cheap bourbon, but as with many bourbons produced in Illinois, it was sweet mash. I think this is in part where the 20th century reputation of inferior quality for sweet mash comes from, producers like this outside of Kentucky making very cheap bourbon. But one shouldn't assume that a good bourbon can't be produced by sweet mash, in fact, I would argue, if you are using old production methods (not lots of bulk chemicals) and you are not using limestone spring water, you would NOT want to sour mash, since this would overly acidify your mash. Hence, why sweet mashes were produced in areas where less alkaline water was used.

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17 hours ago, Silk City Distillers said:

The most interesting part of this hot buttered popcorn, corn-on-the-cob flavor, is that it actually has absolutely nothing to do with the corn.  It's diacetyl, a fermentation byproduct, while yeast an produce it, in a sweet mash, it's more likely going to come from lactobacillus and pediococcus.  This is further amplified by short fermentation timeframes.

While a lot of diacetyl is a fault (though maybe not in corn whiskey), a little bit can really emphasize flavors of butterscotch, toffee, caramel, butter, as well as enhance mouthfeel.

 

Diacetyl is a fault, except when it is not. Same for beer as for whiskey. In fact, I LOVE the affect of diacetyl in appropriate whiskey, and beers for that matter. Often it is a byproduct of "old fashioned" sour mashing, which is the intentional growth of lactobacillus in the beer after fermentation by yeast, and something that sweet mashes were prone to (sour mashing helps prevent it). We do this in our products intentionally. Yes, in the marketplace, we see both good and bad reaction to this. For many new whiskey drinkers, it can draw them into drinking whiskey when modern versions seem too austere or tight to the unaccustomed palate. Not only the diacetyl, but other esters can prevail, giving a fruitier and more floral nose to the whiskey, just as it does for beers. For some experienced whiskey drinkers, they may also find they can enjoy the style as something different from what the majors offer, like expanding from lagers to Belgian ales. But we do get a lot of blowback from "traditional" whiskey experts, who will declare that whiskies should all taste like that overaged, tower-distilled, sour mash that they have been cranking out since prohibition (a little tongue in cheek there, LOL).

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I have only had 2 sweet mash bourbons.  One was aged wrong somehow.  It had a very strong tannic acid flavor.  Also it had a lot of mouth burn and tasted and smelled of heads.  The other seemed well made, but it was lighter and without the character that you typically get with bourbons. It reminded me of Crown Royal.

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Having done both, it’s very hard to differentiate between backset sour mash and acidified and nutrient-dosed sweet mash.  The differences are subtle.  I don’t know about non-acidified mashes, because, well, why would you?  I’ll leave bacterial souring out for a moment.

I’ll say you can distill a cleaner whiskey from a properly mashed and fermented “sweet mash” base, this is a fact.

Backset adds 4 major components to a mash:

Acid - primarily carboxylic acids and primarily acetic and lactic within that category.  Also propionic, butyric, etc.

Nutrient - Backset is very high in nitrogen and yeast derived nutrient. 

High-boiling Alcohols - This is going to be the Propanols, Butanols, Isoamyl Alcohols.

Water - Worth mentioning.

Also worth mentioning the origin has nothing to do with hokus pokus, and everything to do with saving money.  Use less water, save money on acid, utilize nutrient that would otherwise require costly wastewater processing, gaining yield along the way. From the accountant view, it’s a win win.

Except, we are adding a greater amount of high boiling alcohols and carboxylic acids that would typically exist.  Put those together and you get lots of ester-based flavors.  Some good, some bad, but most definitely more flavors than would exist otherwise.

So running tight cuts and greater separation on a Backset sour mash is going to bring you closer to sweet mash, running loose in the sweet will get you closer to sour.

Bacterial sour mashing, in particular late lactic souring will result in a similar increase in carboxylic acids and corresponding esters as dosing Backset would, so realize there is a pretty interesting relationship across all these.

We haven’t even touched on Backset ratios, which vary wildly across producers. I’ll look back through my literature but I believe it’s wider than 5% to 30%.  So do you like 5% sour mash or 30% sour mash?  Would you even know?

Likewise, wooden fermenters that many of those producers use, full of bacteria, primarily lacto.  So you can’t even pigeonhole these guys into one approach, because it’s both.

There is no black and white here.

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