We currently produce and sell a liqueur. We tried finishing the liqueur in cooperage, and it is delicious, now we want to sell it.
The formula was approved by FONL as a liqueur. Upon submission to COLA they rejected the label because of the words “Finished in Whiskey Barrels.”
The Formula did not have any labeling suggestions provided.
I called the TTB this morning, asked how do we denote that the product touches cooperage, and she didn’t have an answer and told me they would call back. She calls back and says that Formula now says it isn’t a liqueur, but rather a DSS, and that a statement of composition is required? But she still didn’t have an answer on how to denote that this is the exact same product as our standard liqueur, but touches cooperage.
Does anyone have experience with barrel Finished liqueurs? Is it not allowed to state cooperage is used in liqueur production? Does putting a liqueur in a barrel really change class to a DSS?
A fellow distiller suggested that we sell it under the same COLA and just change the color of the label, this suggestion doesn’t seem like the correct answer to me?