TNJustin

Anybody else revisting this thread now that WS is doubling their prices? I've been looking at Orchestra as an option to switch to, anyone have experience with them? And how is Hoochware doing now that they've rebranded to Onbatch, anything new?

The trick is to not specify a type of whiskey. Your 180 proof unaged spirit fits the TTB definition of "Whiskey" and as long as you don't claim a specific type, there's no issue. 

I guess what I'm asking is can I modify an approved formula without starting over from scratch? I don't mind adding something, but I don't want to have to redo the corresponding COLA or wait the two month approval time.

I've looked at that page, but I've only found where it addresses label changes, not formula changes. The NaOH is in reference to a flavored spirit, I need to drop the pH to keep the color we use from fading. We've used it in a couple other products and it's not listed on the label, we had no problems with approval there, can you point me to where it says that should be disclosed?

Is it possible to make a change to an approved ttb formula? For example: adding a small amount of sodium hydroxide to balance the pH of an existing product, or changing the bottling proof? I know the formulas allow some leeway in terms of how much of each ingredient is put in, but what if I would like to change something more than that? do I have to submit a totally new formula?