bluestar

No, because then you lose the effect of transpiration. There are 3 effects of barrel storage: extraction, transpiration, and aging. All contribute. Yes, you might be able to reproduce all 3 but sophisticated technology.

Per the CFR, "Malt" stand-alone means malted barley. Any other malt in a whiskey description or type must specific the grain. While the CFR does not call out the latter, that is the TTB's interpretation, probably by extension of "Malt Rye" or "Rye Malt" being an official type in the CFR distinct from "Malt" in the use of malted rye instead of barley.

While there is no equivalent officially, the TTB won't let you use the term unless you are distilling and bottling in a single distillery, since it will be considered misleading. On the other hand, they won't require using the minimum age of the EU.

What you say is correct, except it matters how it was originally classified when originally made! Even if you made it to the specifications of vodka at the start, if you classified it as neutral spirits to begin with, to go to vodka is a reclassification and requires formula, because that is the rule: a formula is required whenever a spirit in one category is processed to classify it into another category.

True, but some taste great. Well, I will speak for myself, mine tastes GREAT! In the end, I feel so long as you tell the consumer what they are buying, they can decide what to purchase. Unfortunately, the TTB rules do not require that a distillery indicate if they have actually distilled the product to the point of being vodka by virtue of plates of separation in the still: hence, you can buy something previously distilled over 190, and then run it through your still, filter, and say it is your distilled vodka. And thus, why there is some negative blow back on using GNS to make vodka and then say you distilled it. I would not have a problem if the TTB required that you could not use the "distilled by" approbation unless your still causes it to change from GNS to vodka by virtue of distilling over 190 proof and filtering. In fact, in one conversation (but not others) I had with the TTB formula folks, I was told that you would have to indicate in your formula that you are distilling to over 190 proof and filtering to use the "distilled by" on the label, as opposed to the "produced by". But if that were so, the TTB COLA folks would have to catch that, when checking the formula. Problem is, you can get a vodka label approved without a formula. BUT, if you are buying GNS (not officially sold as vodka) and redistilling to call it vodka, in fact, you need a formula, because you are changing the classification of the spirit. Many don't realize this.

Come now, that is a bit snarky. Everyone in the industry knows it is so: in the 2000's many states added special craft distillers licenses that made it feasible, both economically and in terms of business plans, to start a small distillery. Geez, you are in IN, and you should know that is true for your state, where there was an existing large and small(er) distillery, but those couple were locked in place, and no others allowed! In our states, IL and MI, prior to craft licenses, there either was a very expensive license with no on-site retail sales capability (IL) or no license whatsoever (MI). And in addition to the limitation at the state level for the majority of states, most localities were not willing to provide licenses either. Craft breweries helped pave the way in many states for local governments to consider licensing craft distilleries. Once these special craft licenses were put in effect in each state, those states saw significant and sometimes explosive growth in the number of craft distilleries. Reference? How about all the craft distilling press in the past 2 decades.

It would be good to post location, both state distilled and current storage location.

You should also charcoal filter it.

First off, your post does not make sense in many ways. What do you mean by large? Cutty Sark is a major blended scotch, there is no distillery. Are you looking to buy a property in Scotland? If you are seriously querying about any distilleries for sale (and I am sure there are many that are available at the right price), you really have to be more specific about size, product, and location.

More likely, it is the trials and tribulations of starting up a new operation. But the advice I would give such a new business, is to clearly and publicly communicate the status, and reason for delays, during start up of operations.

The bottle you pictured has very little, if we use the small light chars, we see much more. But generally, we would not see anything from a 53g char 4, and almost nothing from even a 15g char 4. But we always see something from the smaller barrels with exposed toast. Are your heads fully charred as well? I know some use toasted heads, this may exhibit the same behavior.

Yes, this is flocc of oligosaccharides from barrel aging. Generally, it depends on the type of barrel and size. Large medium to heavy chars don't show much of this behavior. Small light chars, or any direct exposure to toasted oak will have a greater likelihood to form the flocc. You can remove by chill filtering, but it will change the flavor profile and mouth feel of the whiskey. We get this in a couple of our whiskies, but we consider it a feature, not a bug, since we are NCF for a reason.

Yup, that must be what is driving it. Your product is sold and marketed by Palmer's Tropical Beverages, LLC. So, if you are going to put that on as the brand, you may have to make clear the relationship of that company to your distillery. If they are one and the same, then it must be listed as a DBA for the DSP. If in fact they are NOT the same, that is where their suggestion that you label it something like "Distilled and botteld by Cotherman Distilling Company for Palmer's Tropical Beverages, LLC". It depends on the relationship of the distillery to the LLC.

Stick to you guns! Call and ask to speak to a manager for the label division. You are correct, a brand name does not have to have anything in common with the distillery name WHATSOEVER. We have 20 different brands all distilled and sold by us, and none refer descriptively to the distillery name. As long as you have the correct "distilled by" or "produced by" identifier on the label, you should be good. You do have to worry if a brand name somehow suggests something false. For example, if there IS a registered distillery named as your brand, then you might not be able to use that name for your brand. Also, if the name suggests something descriptive that is considered misleading, then you can not use it. For example, a brand like "Rum Spring", but it is not rum.

We usually have no problem using the term "Barrel Reserve" on our labels, although we have had a couple times where one agent did not approve it, but it was approved by another or their supervisor. I doubt you will get away with a front label statement citing "Whiskey Barrels" unless the product is whiskey.

I think I see what could be the problem? You could start with spirit, add natural flavor and sugar, and be a liqueur. You could probably put it into cooperage afterward and still be a liqueur, since any flavor from exposure to wood would be natural extractive. But if you specifically call out you make a liqueur and later place in a whiskey barrel, this means flavoring could be coming from both wood (natural) and residual whiskey components (man-made), and so could be seen as taking it out of the liqueur category into a specialty.

Yeah, I wondered about that, by using the word whiskey, and calling it a liqueur, if the base spirit is not a whiskey, it could be mistaken for a whiskey liqueur, which has a specific meaning in the CFR. But that problem usually shows up with the COLA evaluation, but not the FONL. So, you may be right, this initially is what tripped the COLA rejection, but still does not explain the FONL reclassification.

You could push back, although I would have someone read over your formulation to make sure something else isn't tripping the DSS classification. They make mistakes, and more importantly, you own their mistake, meaning if they later figure out it is classified wrong, they can make you change it back. Do you "age" the product before or after you add the sugar?

To start, you mean you had a formula approved as a liqueur where you did not describe finishing it in barrels? And then you submitted a COLA request that included "Finished in Whiskey Barrels" on the label? Well, of course if so, that would fail, because the label and formula did not match. So now the question is with FONL, why is it approved as a DSS instead of a liqueur if it has spent time in a barrel. It can't be because it has been in a barrel per se: there are many liqueurs based on whiskey as the source material. You might want to ask the question in just that way to someone in formulas, why does spending time in barrel prevent it from being a liqueur? 5.40 (5) (d) prohibits age statements for BOTH liqueurs and DSS, so I don't see why if that phrase was allowed for one, it is not allowed for the other, as far as age statement. So, they are not regarding it as an age statement. A liqueur is something with at least 2.5% sugar and extract flavors from natural materials. Perhaps you need to point out to them that oak barrels are natural materials, and any extract that may result from them would be just part of what constitutes the total of extractive materials for making the liqueur?

Similar question, for Arizona...

Yes, we put more on there than we must, but we also want it clearly labeled with the information that the retailer might want to see on the case, like number and size of bottles. We group all the "quantity" information together, so it is clear to find and verify self-consistency. Like putting both volume in liters and proof gallons, since most don't know what proof gallons are, etc.

This is an important point, to use NEMA 4 or 4x enclosures anywhere near distillation or storage of spirit. And since you are likely going to be using SSRs, not just mechanical relays, for power control, you also have to make sure you have adequately sized heat sinks for the SSRs, not only to cool them, but to avoid getting so hot themselves that the heat sinks or box itself gets to too high a temperature for potential exposure to ethanol vapor. Our box was so good, that when we did have a catastrophic failure (burn up) of an SSR, we only knew because those elements went out. The vaporized remains of the SSR (including odor) was completely contained in the sealed box, as it should be.

We include something like this, for example: 12 x 375ML Bottles • 44% Alc. by Vol. • 88 Proof 4.5 Liters Total Volume • 1.05 Proof Gallons

For the control box: Looks like 6 switched SSRs, instead of 5? And there are a couple more SSRs, are those for the motor control, or something else? Looks like each of the heating elements is set up for single phase 120?

In the end, it will be up to who at the TTB reviews your application. But the general answer is no. You can pass through space you control that is not bonded premise to get to bonded premise. But you can't do the reverse, or at least that can't be the official entrance to that space. For example, I know a distillery that had to add a bathroom to a tasting room because the existing bathroom was in the bonded premise, and that could not be treated as publicly accessible, as required by code. And you might have fire code issues with egress, as well, having to go from a public assembly or mercantile area through a hazardous or industrial space for exit. Without seeing layout, it is hard to speculate. But what you will likely need to do is create an entrance lobby that is not bonded premise on the first floor that both exits outside and is the location of the base of the flight of stairs. And while there have been some distilleries that have had less than floor-to-ceiling wall separations of bonded premise from other space, the rule essentially says you can't do that. Best might be to give the drawings to a TTB field officer to review for you.