Charles@AEppelTreow

Wisconsin uses the term 'three tier system' in the 'legislative findings/intent' preamble in two different chapters of statutes. The chapter on 'fair dealerships' goes so far as to say that it is the 'intent of the legislature to protect and promote alcohol wholesalers in order to foster competition in the middle tier.' For the other tiers, the stated intent is 'to restrict and restrain' (in the words of the top regulator.) Federal regulation hasn't always been more open than State - but in this moment, I'd agree with Chuck.

I stand corrected. It turns out you have to look beyond the alcohol regs. The beer franchise provisions are in the booze regs, the spirits are elsewhere. And wine might be excluded entirely - but I will grant that not falling under the regs, and proving it in court are two totally different things.

Title 27 sets out a two tier system. Look at the chapters on the '4 Noes', ummm... chapters 6 (Tied House), 8 (Exclusive Outlet), 10 (Commercial Bribery) and 11 (Consignment Sales). All the prohibitions are set out in terms of 'Industry members' and 'retailers' and IMs are defined as producers and wholesalers. (And a unified single proprietor being a special case.) In Wisconsin, the 4 Noes are embodied in a section of Statutes 125 titled 'Relations with Retailers'. That section pretty much reflects the CFR chapters. But WI goes further and applies Tied House to the producer / wholesaler tier. On the other hand, we (in WI) don't have to deal with franchise law (at least for wine/spirits) - which I view as the inverse of Exclusive Outlet. Interesting system - bar IMs from making exclusive deals with retailers - but mandate it for producers & wholesalers. WI also mandates a certain path to market. Who can sell to whom. The Feds don't seem to delve into that side at all. It hadn't occured to me before - but my notes above show two side to the 'three tier system'. Once side deals with money and market influence. The CFR deals with that, and makes it two tiers. The other side deals with physical flow of alcohol - forcing through a specific value (ha) chain. The States seem to have created that system - and it surely has different motives and effects.

Oh - and 'applejack' is already on the 'known' list in the beverage manual. It's either a synonym for apple brandy, or in the case of 'blended applejack', an apple brandy, grain spirit blend. That doesn't match the colloquial meaning of 'fermented cider concentrated by fractional crystallization' - but that meaning of 'jacking' may be regional.

I made an apple dessert wine with the fanciful name 'pommeaux'. White Oak Cider made one simply called 'pommeau'. 'Pommeau' isn't in the list of recognized designations of class and type - so it can't stand alone on the bottle. The fine print says 'apple dessert wine'. I had no trouble getting my label approved, but "pommeau d'normandie" now has it's own AOC, and I've heard of other cidermakers having trouble with label approvals. I don't know the details - I just hear some stories. This falls in line with Ralph's issues with US whiskeys going to the UK, and the scare about an absinthe AOC. Is there a treaty mechanism to automatically exclude US labeling whenever the EU approves a new Appellation? I can't find one - I can only find explicit lists, periodically renegiotiated. Pommeau is not on that list - but I still hear stories. Treaty, or overeager regulator? I don't know. In any case, Lukas, I think you need to sit down with the CFR. Look at the Beverage Labeling Manual. Call the folks at the ALFD (Labeling and Formuation Division). At 80 proof, you need to watch the dissolved solids level. Under that, it's not brandy - but that doesn't mean that you can't make it - just that you have to be careful about what you call it. Liqueurs have (I think) a _lower_ limit on the dissolved solids. 'Dessert wine' is between 14-21%abv (21-24% in special cases) but is the product of a bonded winery - not a DSP. Lots of things can be made - specialty spirit drinks can be whatever you can get a formula and an honest description of class and type and label approved for.

An antioxidant, antibacterial, metabolic intermediate binder and 3 other jobs, I believe. Mostly pointless to a distiller. Anything oak aged is going to be oxidized - on purpose. Spirits are generally beyond the need for microbial control. And distillers mostly use their mash and wash quickly, before it needs protection from sulfite. That said, sulfite is allowed in wine, and anything approved for use in wine is allowed for wine distilling material. Plus, there's a second list of things allowed in distilling material made in a bonded winery in addition to the approved-for-wine list. If you received wine from a bonded winery, and the sulfite level was really high, you can knock it down with hydrogen peroxide. I find that in the 30-70ppm range, it simply blows off during distillation - mostly in the heads fraction. Sulfite has a a 'burnt match' like pungency. It's completely different from reduced sulfur (H2S and its kin). I don't think you can add sulfites to a spirit for self stability. Even with a formula. But the TTB ALFD would be the definitive resource.

The first distributor I contacted told me (to my face) that I should sell to him at cost, since making money from his hard work would be immoral.

A Saturn '7'? That _would_ be impressive. The points will vary somewhat. In WI, I pay state excise tax.

Thanks Steve, My paperwork has been in for about a month. I was hoping for a relatively quick turn around, but they say is't running about 6 weeks for a registration amendment.

Just for the sake of completeness - I did locate the EU Agreement on Spirits from 1994. But it looks laughably small. Paragraph B has the bit that gives Ralph conniptions (and quitely rightly.) http://tcc.export.gov/Trade_Agreements/All_Trade_Agreements/exp_002818.asp

The TTB has an interesting set of pages in the wine section that descibes the current agreement/negotiation with the EU about wine issues - both labeling and manufacturing practices. http://www.ttb.gov/agreements/us_ec_wine_agreement.shtml It at least gives an idea of how the process works (or fails to work - it looks like there are as much caveat as treaty). I haven't seen the equivalent for spirits. Also, I haven't quite figured out the TTBs approach to European AOCs. The Agreement above has a huge explicit list of reserved origin names (as cowdery mentions in an earlier post). On the other hand, this list doesn't have any of the cider/pommeau AOCs that have arisen. And yet, I've been told by fellow cidermakers of COLA refusals based on the mere existance of AOCs with a similar name. Is that over-anticipatory regulation? Or the result of agreements I haven't found? It's a very complex topic.

Work in progress. Reversing the shell and tube might work - if it actually gave you a bigger cross section - and hence a lower gas velocity. I made a parallel tube in shell. Twice the length, I think it was 4 times the cross section, and 10 times the surface area. That's from memory. I have the figures around here somewhere.

I haven't run without it after a deliberate control experiment. It boosts proof by 5-10 points. But it has a bigger impact on the hearts to tails ratio. It reduces the proof gallons of tails per run. With the same number of proof gallons going in, you get more out as hearts (cut by falvor and proof). My observations on running my Col. Wilson still with a GA ridge head: The lbs/hour coming out depends mostly on the heat going in. It's nearly constant for any portion of the run. The proof drops nearly linearly with time for a given heat imput. It has a slight downward curvature, starts to be noticable toward the end of a phase. The proof gallons of tails is fairly constant, whether run faster or slower or with a higher ABV in the wash. (If the starting wash has more ABV, you get more hearts and the same pf*gal of tails. If it's too low, you get far fewer hearts - and the same amount of tails.) The bubble plate reduces the amount of tails by about half. Maybe more. The still appears product-cooling limited. Try to turn the heat up to run faster and at lower proof, and the spirits come out hot. I've built a new condenser, but haven't finished the lyne arm. The new condenser will let me run a higher heat input and still get cool spirits out. The could let me do something like a stripping run.

Two bits - I'm interested in Associating with distillers. While there may be value in forming a guild or union that credentials its members - it's not something _I'm_ currently interested in. And I don't think the Artist and Craftman have to be the same person - or that Art needs Craft as a foundation. It may help - but a jewelery designer can make a beautiful piece (once) with just enough skills and luck. But they don't have to have the Craft needed to put out sets of fine silverware. On the other hand, a distiller_y_ (rather than distiller) probably needs both.

I'm an Artist when I sit down with raw materials, experience their qualities, and am inspired to treat them in a certain fashion and in certain combinations. (For me, that can go back to cultivar selections and growing practices.) I'm a Craftsman when I go into the 'shop' to execute that inspired plan - converting ingredients into a packaged beverage that a consumer can pick up and enjoy (and thus share the idea the artist had). I'm a Master in the practical sense that I'm the shop boss - and in charge. And that accountibility falls to me (unless I've delegated it - but I do the delegating.) I'm a Student whenever I realize how little I know. Daily. I think distilling can be craft or art, depending on which aspect you're participating in. Either way, I think it's something you practice - like medicine, law and architechure.

You use a dephlegmator to control the reflux ratio. You could simply have an empty section of column up on top (I suppose it would be a helmet of sorts) that would provide some air/wall-driven reflux to fill your top plate. But then you have to take what you get - a certain amount of vapor falls into the lyne arm and a certain amount refluxes back. And that ratio would change over the course of the run as the composition of the liquid boiling in the top plate changed. With an actively cooled internal condenser, you can vary the amount of condensation sent back down over the run so it's always the same fraction. Or near it. The end effect is that the proof vs time curve is flatter - you get more out at higher proof. With no dephlegmator, the proof changes continuously during a run. It's a pretty linear decline.

I've pondered a solar alquitar as a stripping still. But I suspect the wash would go bad in the time it took. And I don't know how much of the alcohol you'd get out.

I've got that plot - an XY diagram in chem-speak - but it's in mole fraction on both axes. Not real hard to convert. The other thing is that the curve is so steep at low ABV (<20%) that it's hard to read accurately.

Wonder if someone new is trying to make a name for themselves. For purposes of cross reference - here are the rules for Bonded Winery - taken from the ttb site. here's the link: http://www.ttb.gov/rulings/80-19.htm And here's the text. Note that not only are functions allowed on the bonded premises - and the IRC code is referenced, but that serving of tax free wine is allowed. I wouldn't expect that (the taxfree bit) for spirits, since there aren't the equivalent testing and tasting allowances for spirits. But I betcha that the rest of the principle applies. ATF Ruling 80-19 The Bureau of Alcohol, Tobacco and Firearms issues this ruling to state its position concerning the use of bonded wine cellar premises for hosting occasional special events such as dinners, luncheons, and similar group functions at which wine and food are served. The Bureau has received requests from proprietors of bonded wine cellars for permission to utilize selected portions of their bonded premises as sites for dinners, luncheons, and similar special events. On these occasions, wine is served to create goodwill and/or to introduce a new product. Although the event could be held in an off-bond area of the general winery premises, a portion of the bonded is selected so that the guests may enjoy the novelty and ambience of a bonded wine cellar. In most instances, the Bureau has approved a winemaker's application and has permitted the proprietor to serve wine, free of tax, at the special event. The Bureau has evaluated its position, concerning these events and issues this ruling to facilitate the hosting of special events by proprietors of bonded wine cellars In addition to the operations specifically described in Section 5351 of the Internal Revenue Code, Section 5361 authorizes such other operations as may be conducted in a manner that will not jeopardize the revenue or conflict with wine operations. The implementing regulation, 27 CFR 240.134, authorizes the Director to make a finding that other operations not specifically provided for in the provisions of Part 240, may be conducted in a manner that will not jeopardize the revenue, conflict with wine operations or be contrary to the law. The Director has found that the holding of an occasional special event, such as a dinner, luncheon, or similar group function, on the bonded premises of a bonded wine cellar at which wine and food are served, is an operation which is not contrary to law and may be conducted on bonded premises in a manner that will not jeopardize the revenue or conflict with wine operations provided the proprietor serves only tax-free wine, maintains records to document the types and quantities of wine used for such purposes, and receives no reimbursement for food, wine, or use of the bonded premises for the special event. (Under the provisions of 26 U.S.C. 5351, 5361, and 27 CFR 240.130, taxpaid wine may not be served on bonded winery premises.) Accordingly, it is held that, upon the receipt of an application filed pursuant to 27 CFR 240.134, the ATF regional regulatory administrator may grant the proprietor continuing authority to conduct occasional special events on bonded wine cellar premises on the conditions that the proprietor serve only tax-free wine, maintain records of the types and quantities of wines used for such purposes, and receive no reimbursement for the food, wine, or use of the bonded premises for these special events. In addition, Section 5372 specifically states that wine may be utilized in any bonded wine cellar for testing, tasting, or sampling, free of tax. The serving of wine, free of tax, at such a luncheon, dinner, or other special event, on bonded winery premises, may be considered as a bona fide use of wine within the scope of the tax-free testing, tasting, and sampling provisions of 26 U.S.C. 5372. Accordingly, it is further held, pursuant to 26 U.S.C. 5372, that a proprietor may serve wine, free of tax, on the bonded premises of a bonded wine cellar on the occasion of such special events. 27 CFR 240.134

From 27 CFR 19.11 Container. A receptacle, vessel, or form of bottle, can, package, tank or pipeline (where specifically included) used or capable of being used to contain, store, transfer, convey, remove, or withdraw spirits and denatured spirits. As compared to: Liquor bottle. A bottle made of glass or earthenware, or of other suitable material approved by the Food and Drug Administration, which has been designed or is intended for use as a container for distilled spirits for sale for beverage purposes and which has been determined by the Director to protect the revenue adequately. or Package. A cask or barrel or similar wooden container, or a drum or similar metal container. I seem to recall that there are some finer distinctions deeper in Chapter 19. Especially for packages > or < 5 gallon. But I can't recall what they are off hand.

No plans to stack more. One - it turns out I'm not good enough at brazing to make something that fits the existing pot and doesn't leak (at the same time). Two - since I'm focused on brandy, the proof I'm getting is fine, now that the tails are reduced. And I think that the results show it must puddle. At least half an inch. At least once the reflux is flowing - it does't hold anytthing when the flow stops. I put it under a tap in the sink and play around with it. I was also concerned that the outer edge, wedged against the side wall, would leak. And it must - but I suspect that there's enough reflux to fill up over that edge, too - and the leaks just go to more bubbling. I made this with a pattern laid out in powerpoint. Sized to the real column. Taped to sheet copper and then cut it out with tin snips, bent it to shape and tacked/brazed the two pieces together. I collected apparant proof and weight data every 15 min for the 5 hours it takes to run. The proof drops in a nearly linear fashion for almost the entire run. The weight/min stays nearly constant. Well - two phases. I set one heat input for hearts and step it up for tails. So two weight/min and two delta-proof/min. I think it takes the variable reflux to hold the proof flat (so the weight/min drops instead).

Sketch...

Top and bottom pics

I have a Colonel Wilson 20 gal still with the Georgia Ridge head. I'm working my way through several modifications, and thought I'd share my experiences as I go. I think the Colonel's stills are most notable for affordability. And that the price comes with several hefty limitations. So I'm trying to work out ways to improve the operation of my little still, and not break the bank. I'm looking at 3 mods to the still itself. Improved rectification, improved condensation, and variable reflux. I've just finished some detailed data collect on the first mod. Improving rectification / Adding a bubble plate. This has taken several tries before I've found a solution I'm happy with. I tried loosely packing the GA Ridge head with copper scrubbing pads - and pulled them out the first time I decided I needed to clean them - because I couldn't do it in place. And the state of the pads was simply scary. The second attempt took more brazing skills than I have. The third try is made out of two pieces of sheet copper and slips into the bottom on the column. It can be easily removed for cleaning. I'll post a picture here, or on my cidery's facebook page. (Aeppeltreow.Ciders) The test wine was an 11%ABV pear wine. I have some nice curves, but the summary is that without the plate, 62% of the proof gallons collected comes out above 130pf (133pg average) and with the plate 83% are >130pf (148pf). So 15 proof higher, and less than half the tails to rework. The plate run took 15 minutes longer.

I try to price to match other retailers. In almost 10 years, I've had a few complaints (one rather intense) that my pricing is higher than some other retailers. It's a moderately common expectation that prices at the cidery will be cheaper - like a factory outlet store. I explain with two points: 1) I can _suggest_ a retail price. I can't order it. There are retailers who accept a lower margin and underprice me. They do it on purpose, since that's _their_ business model. 2) You get a lot more coming directly to the cidery than just the product. You get me, my partner orchard, you get the sampling, the experience and the education about what we are and what we do. It's worked so far. Regarding side items: hasn't worked for us. Amounts to about 3% of tasting room revenue. Except for cheese - and then only when we sample it out like the rest of the products.