Julius

Are you labeling as “Potato Vodka?”

We recieved some samples from Berlin Packaging and they are top notch. 

Is the new company Great American Craft?

Following

Is this still available?

Following! I am assuming these are production barrels made for sherry cask finishing, and not actual solera barrels?

Would love to know where Insurance Man went, or what company people in Colorado are using for insurance.

Thanks so much Dave. I hope to buy you a drink one day. 

1 hour ago, Tom Lenerz said:

Using the public registry, you can see it is not (in the eyes of the TTB) a straight bourbon whiskey, but indeed a whiskey specialty as described above. It also required a formula. See the links attached 

Parkers: https://www.ttbonline.gov/colasonline/viewColaDetails.do?action=publicDisplaySearchBasic&ttbid=18159001000469

Angels Envy: https://www.ttbonline.gov/colasonline/viewColaDetails.do?action=publicDisplaySearchBasic&ttbid=13093001000246

What other class/types are missing from the chapter 4 table? “Whiskey Specialty” is no where to be seen?

On 8/15/2018 at 12:14 AM, dhdunbar said:

The rules for bourbon and for other American type whiskeys are not the same, even though they are of the same class and type.  This is the result of a policy developed over time.  Before TTB issued the ruling on general use formulas, you could not find any mention of the issues, at least as far as I know, in any higher level documents, i.e., documents in which TTB expresses an official position on a matter in a binding way.  You could find it, without explanation, in the Beverage Alcohol Manual, but as much as people view that as a biblical source for label information, it does not have the authority of regulation or ruling.   

Clearly, placing a whiskey,  into a used port barrel adds something, color or flavor, to the whiskey.  If not, why else go to the trouble, unless, of course, one is searching for a nitch in which to market.  At any rate, TTB is willing to accept an argument that finishing malt whiskey, or rye, in used sherry, etc barrels is consistent with established trade usage  and so does not change the class and type under the provisions of 5.23.  However, it holds bourbon to a different standard. 

Bourbon is the sacrosanct American type whiskey; it is  the distinctive product of the United States.  So for reasons which are lost to history - they were never the subject of rulemaking that I know of -  TTB appears to limit what TTB will allow before treatment of bourbon transforms it to a specialty which is marketed with a fanciful name and truthful and adequate statement of composition.    As I said, I can't explain how TTB makes those connections, but it does.  I think it is an evolved position. 

Notwithstanding that, creative people devise ways of splitting the statement of composition into phrases that appear on separate lines on the label and TTB approves the labels, creating the impression that the product is a bourbon, when the label is approved as a specialty.

That said, here is the official position as stated in the general formula ruling, beginning with the explanation and ending with the ruling (See - https://ttb.gov/rulings/2016-3.pdf)

• Furthermore, Chapter 7 of the Distilled Spirits Beverage Alcohol Manual (BAM) (TTB P 5110.7 (04/2007)) provides that bourbon whisky may not contain any amount of added coloring, flavoring or blending materials. This reflects the determination by our predecessor agency, the Bureau of Alcohol, Tobacco and Firearms (ATF), that added coloring, flavoring, or blending materials are not customarily employed in the production of bourbon whisky in accordance with established trade usage.
• Held further, no coloring, flavoring, or blending materials may be used in the production of spirits designated as “bourbon whisky” in accordance with § 5.22(b)(1)(i) or “straight” whisky in accordance with § 5.22(b)(1)(iii).

Check, for example, the difference in the TTB approvals for Angels Envy products.  You can find them on line in the public COLA database.

I think these hair splitting machinations  have sometimes eluded the specialists in the past.  I think they are now aware of these provisions.   But given the ratio of COLA's to specialists, I'm confident some will still slip through.  And I doubt that one consumer in a 1000 gives a damn about that issue.  

 

 

So how does this fit into that logic?

https://www.thespiritsbusiness.com/2018/07/heaven-hill-uses-orange-curacao-barrels-to-finish-bourbon/

Straight Bourbon Whiskey finished in orange curaçao barrels. 

Would love to know what you find. 

From my understanding, you do not need a formula approval for anything you have proposed. Except the “White whiskey” which you probably wont get approved at all. You can call it “White Dog” or Moonshine, or premium dogshit. But unless you get lucky with a clueless TTB agent, the words White and Whiskey wont go next to each other on a label.

As it comes off the still it is not yet whiskey, it has to touch cooperage. If it goes into used, or uncharred new barrels, it is corn whiskey. If it goes into new American oak, it is bourbon. 

Good luck trying to get a “White Whiskey” COLA. 

1 hour ago, bluestar said:

We have done 5g for 2 years, twice now. about 60% loss as angel's share. This is for a tight grain oak (Minnesota). For similar oak, we don't see anywhere near that much loss in a 15g in 2 years, closer to 30%. YMMV

Our dry mountain climate does not like small barrels. Maybe a more humid climate or supplemental humidification in storage would be more suitable for small barrels. 

We have harvested 15, 15gallon barrels, each was 50%-70% angel share after 30 months. Harvesting 8, 30 gallon barrels saw 35%-55% angel share at 36 months. We are in a very dry climate. YMMV

We have had great luck with the Gibbs Brothers 3 gallon barrels. ~10% angel share annually

19 hours ago, Silk City Distillers said:

This may have labeling implications.  For example, if you dump bourbon into used oak, the clock stops. At some point, you are going to wonder if it just makes more economic and operational sense to move to slightly larger barrels.

Economically, the price difference between 5g -> 10g -> 15g is minimal.  If you are dumping a 5g at the 6 month mark, and letting it sit for 6 more months, why not just age in a 10?  Likewise, dump a 10g at the 1 year mark and let it mellow for 6 months, why not just use a 15g?

 

 

And if you plan on leaving it in a 15gal for more than 2 years be prepared for 50%+ angel share. 

What state were they distilled in and where are they currently located?

4 hours ago, bluestar said:

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.

I believe this is the issue they took with it. We eliminated the word barrel and we got approval. It’s a product we have to hand sell any, oh well. 

After a lot of BS from Cola, we are just going to completely eliminate the word barrel on the label and replace with “reserve’ and just reference barrels in marketing material. What a shit show in DC.

12 minutes ago, bluestar said:

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?

Sugar added before adding to barrels. We take the final product that would normally go into bottles, and barrel it. I’m expecting a call from them today, I will report back what they say.

21 minutes ago, bluestar said:

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?

No. My formula clearly states the barrel finishing process and subsequent proofing. The formula matches the label explicitly. 

FONL classified it as a liqueur initially. The agent on the phone spent ten minutes talking to someone and then came back and said it’s not a liqueur it’s a DSS. 

I don’t understand why putting a liqueur in cooperage makes it not a liqueur any more 

59 minutes ago, Jedd Haas said:

What was the exact language of the rejection? If they rejected it as an age statement, then you simply have to find some other language to use that explains the use of the barrel.

• You may not make false or misleading statements on labels. 27 CFR 5.42

• Additional Clarification:
• You will need to remove "Finish in Whiskey Barrels" on the liqueur product.

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?

What companies filter thru limestone?

Who filters their vodka thru limestone?

Blue Label Digital Printing is awesome. Pleasure to work with.