Charles@AEppelTreow

I always apply Hanlon's Razor, and assume ignorance before villainy. I'm more frustrated at the TTB's inconsistent application of the regs that I am at the inconsistent labels I've seen on possible competitors bottles. And even there, I don't think the TTB is a villian. At least out to a couple decimal places. But how is one to improve one's systems without data? Say the TTB is developing automated aids to help with approval screening. Tools that pull up the pertainent regs and common pitfalls alongside the COLA for the reviewer. I've heard reviewers make comments that suggest this is done. I can spot two failure mode easy - the guides have holes in them, or the info originally entered into the database about the label/product is faulty. I know the latter happens - I see bad origin and product class/type codes on my own returned/approved COLAs. If someone isn't will to call out mistakes by specific examples, how can the TTB improve? That's the end goal, isn't it? Improve the system, rather than hassle our peers? At this point, I should live up to my own words and cough up some examples. <mumble/> whichi'llgettorealsoonnowyesofcourse </mumble>

Are you only interested in spirits? I tend to watch cider - or rather, the place where cider and apple wine overlap, since <7%abv cider doesn't get/need a COLA.

From the wine journals, I gather that oxidation prevention in the bottle is threefold. Minimize the oxygen in the bottle after filling. Slow the rate of new oxygen diffusing into the bottle (through the closure) and scavenge any oxygen that gets in via chemical reaction. (Caveat, I'm now seeing articles about going too far in the reducing direction - trace O2 is important for aging - in wines.) Working backwards: Wineries mostly use sulfite for scavenging. Maybe a distillery could use ascorbic acid? It's fragile stuff - even if it's in the fruit, it might not survive crushing and macerating. The Vitamin C in cider apples, or Calville Blanc d'Hiver doesn't survive pressing, for instance. What kind of closure do you use? Bar top? Short or long corks? Micro agglomerated? Natural cork? Synthetic. ROPP? Go back through issues of Practical Winery & Vineyard - there are multiple articles talking about O2 diffusion rates for different closures. The only one I haven't seen listed is bartop/t-cork. i shudder to think how leaky they might be. The lowest is usually ROPP. The second lowest is the double-disk agglomerated cork. Those have other failure modes, though, so they are generally considered appropriate for young wines. (I haven't had issues with though out to the decade time frame) Do you strip oxygen out of the product with a N2 sparge? Do you do an inert purge of the bottle before fill? After fill?

And there are specific regulatations for allowing and handling runouts of labels, for when the TTB decides to let you use up the end of the lot, rather than forcing you to scrap the labels, and perhaps re-label. That's fine - exception handling is laid out. But what does it take to trigger that? How big a player do you have to be to have your voice heard - and acted on? A complaint from little old me, about a fellow industry member using value marketing terms inappropriately has yielded zip. I've been told 'that was a mistake, and there's nothing we can do about it (except not repeating the mistake with you)' more than once. Should complaints/inquiries go somewhere other than the ALFD?

Nick, I don't think it's like breaking a law a physics - where you simply can't. Reality is. From time to time, measuring technology improves to the point where we can see small discrepancies and call it 'new physics'. But they were really there all along. I've certainly seen COLAs that violate Beverage Manual rules. I called them (The TTB) on a sparkling cider that listed a vintage year and an American Viticultural Area appellation on the label. Neither off which are allowed on fruit wines. The agent I spoke with looked it up and said 'Ah, it was keyed into the database as a sparkling wine, rather than an apple wine, so the system would have brought up the wrong list of items for the reviewing agent to verify . No, we won't revoke it, and No, you can't have a label like it, just because that one got through.' If that doesn't count as mistakenly issued, I don't know what does. The flip side question is 'What do they (the TTB) do about it when they discover it?' That seems to be as hit and miss as the original mistake. I asked the agents at one of the compliance/education seminars about a dessert wine label COLA that I had that mentioned the use of spirits for fortification. A no-no, unless it's spirits of a different fruit - when it's mandatory. They said 'it would be nice if you turned it back in - but there's nothing we can do about it otherwise.' But that's in direct contradiction to the stories we hear here of revoked COLAs (or have we heard them here??) Or the big news last year of one of the spiked energy drinks that had its COLAs revoked after policital pressure was applied. The ways of God, Girls and Government are all mysterious, and it's not given to Man to understand them. .

If Politics is the Art of the Possible, is Marketing the Art of the Impossible?

'Digestif', Guy. 'Aperitif' is a class/type of wine - Different volume of the Beverage Manual :-) I banged my head against that wall when I sought an 'apple vermouth' label. No go. You can have an apple aperitif - but vermouth is specifically grape based. All in the name of protecting consumers who don't know what either 'vermouth', or 'aperitif' mean in the first place.

Take a look at 27 CFR 19.143

I use the calculation method out of Winery Technology & Operations (Margalit, 1996), which is based on amount of bound sulfite. The dose above sounds like it's in the ballpack - but it depends on how sulfite is actually there.

Oh yes, we're after the Great ReNumbering. Had to go fetch a new copy of Chapter 19. Don't get too wrapped up in that. You can have 'adjacent' premises. You may need separate areas for storage - protecting the revenue. Hop down to Wollershiem and talk to Phillipe. Take a look at how he's got the DSP 'separated' from the BW and tasting room. My DSP production area is a 4x8 foot square. Just big enough to hold the still and some spirits in progress. The rest of the production room (30x20, or so) is BW, but can alternate premises with the DSP when I need the space to set up the bottling line. A number of places in MI are set up the same way.

Paragraph #? I get lost in the section/subsection. But the number helps. And you'll have to watch WI law closely. The Manufacturer/rectifier might have to be a whole separate company. Site doesn't matter so much as ownership, in WI, I'm afraid. Roger Johnson at the DOR is the primary resource on that. And he's good, as long as you ask direct questions.

How would it violate 27 CFR? Or isn't there room for clear segregation? Mind you, that segregation is in the eye of the reviewer. At AeppelTreow, we have small areas, non-contiguous, that are permanently DSP. Marked only by paint on the floor. And a bigger portion that alternates premises with the technically adjacent BW. It required some special wording in the bond to cover spirits travelling through the Bonded Winery. I haven't been to Moosejaw, I'm afraid. Only get to the Dells once a year :-)

Pardon? Marianne is even less on-line than Milissa. Milissa does the artwork for our labels. The original paintings. I just jockey them about in Illustrator and add some text.

Hurray for more lady distillers. My wife, Milissa, is our Distillatrix. But she's adamantly unconnected in the digital age. A steadfast Luddite.

Agreed, you'll be venturing into the 'liquor' fifth of Chapter 125. Not straight-forward as an add-on - Guy points out the entanglement of other spirits, but it extends to wine and liqueurs, too. To keep a well stocked bar, you might have to make it all. Charles AeppelTreow Winery & Distillery Burlington (Yes the fifth pun in intentional, but Chapter 125 is roughly equal parts definitions, retail, beer, liquor (including wine) and 'relations with industry members'.)

Think about freezer charges and the cost and time of getting it to the freezer and back. It's not trivial to get large blobs of fruit thawed without damage / oxidation. I press apples and pears and send the _juice_ to the freezer, rather than sending the fruit.

I also. Just look for the kilt.

I think the federal requirements for things like approved production methods, formulas and labels, would complicate a DSP version of a brew-on-premise idea. I know that the WI DOR isn't comfortable with brew-on-premise, even for beer. A friend was looking at getting a special permit type created - but I don't recall how it ended up. WI DATCP only allowed the first mobile wine bottling line this past year - and apprarent that was a trial for the people involved. i know of only one vint-on-premise shop in the region. It was in IL, and is out of business. I bought their corker. In WI, (praise be to The Great Rehorst), a DSP (Manufacturer in WI permitting) may sell their own products from their site without a retail liquor permit. It was easier to stick in the exception that way, rather than to rewrite the whole 125.69 'relations with retailers' subsection. But you need a distributor to reach offsite. And you can't use one of the winery co-op distributors. And there's no small producer exception for manufacturers or wineries. And you can't license to be a producer and a wholesaler. It's all there in Statutes 125 and Tax Code 8. Chapter 125 has seen a lot of revision in recent years, and was never very big. The distributors closed up most loopholes in The Year of Great Sadness. (when the wineries lost self distribution)

'Sorghum spirits colored and flavored with apple, cherry and chestnut wood'. A specialty spirit. Which doesn't work well away from the tasting room, where we can explain it. So I reformulated to include (used) oak barrel aging before the other woods, and the product is now simply 'whiskey' with no sub-type. Still have to disclose the use of non-oak woods on the label.

Wine America sent out a letter to that effect. OMB researching what it would take, etc, etc.

A simple grape crusher will work for the cherries. You can set the rollers further apart and hardly ever crack a pit. I have a press, too, so I ferment, press and distill the wine. Still working on the larger fruit. Hand crushed one batch. Won't again.

I used GVC.net recently. It went smoothly. They have some more obscure things like orifice 'gaskets'.

7 labels. 6 approved original submissions. 1 resubmitted without change, but with many discussions about adding woodchips to whiskey.

1 micron pleated filter. Bottling tank is under a few pounds of pressure to drive the flow.

I've been told that some coopers use a dusting of flour in the barrel for a darker or more even toast. I don't have the details. But gluten might come into some spirits that way, rather than through the still.