We're working on what our gin will taste like, and it seems we've discovered something odd in the TTB regulations. I've always heard that the botanicals are added during a third pass through the still (i.e., after a stripping run and finishing run to produce the spirit, or using NGS produced elsewhere). What the TTB just told us is that doing this third run makes our gin 'redistilled' and thus we have to go through formula submission. However, if we put the botanicals into the second, finishing run, then we are making 'distilled gin' and do not need to submit a formula. Seems like an odd distinction to draw, but we wouldn't mind saving a step of TTB paperwork.
However, given this, why do we seemingly always hear that botanicals get added on a third run? Does anyone know if doing it in the second run has any down side?
Thanks,
Hawk Pingree
San Juan Island Distillery