JailBreak

@dhdunbar That makes a lot of sense! Thanks for explaining that in such a clear and concise way! Do you have any light to shed on the last part concerning partial harvests and aging? I know the clock stops if you were to dump the whiskey from the barrel, but does it stop if you partially harvest an amount out?

Also, I have really been enjoying reading the different methods and procedures, do go on fellas!

That's what I figured. Thanks for all the insight!

@Southernhighlander Thanks for the information! I did not know that about the two types of mash. I knew what they were, just didn't know one may be better than the other for specific products. Like I said earlier, these are purely hypothetical questions to help me further understand some TTB regulations. I will definitely remember your advice if I ever produce a corn whiskey though! 

A little off topic but how would you produce that very first batch of sour mash?

Am I the only one who has a problem with that? No part of the process changes and the S.O.I. are met either way. But the way it is, 3 separate but identical batches=no formula. One batch split into three products=2 to 3 formulas. The real kicker is, unless you disclose your entire process, no one would be able to tell the difference. 

What if you make a batch as corn whiskey then realize it is a little funkier than you wanted so you toss it in a barrel to become bourbon instead? Or the other way around, produce a batch of 'bourbon' but really enjoy the flavor as a new make?  Just seems like a waste of resources and a burden on the distiller to me.

Thanks for the input! Any answers to the barrel questions?

Yeah I understand the distinction between the two. That wasn't really what my hypothetical was getting at. What it is getting at is, if I were to do a SINGLE 'batch' (mash, ferment, stripping run, finishing run) with that grain bill, I am able to make 3 products out of it that normally do not require formula approval. But what do I call the distillate fresh off the still? And would I need formula approval if I were to call it corn whiskey then put it into a barrel and call it bourbon, since I am changing class/type? Or what if I were to just call it the general class 'whiskey', would I need formula approval for all 3? 

One of the only questions not concerning formula requirements is, does the aging clock stop if you partial harvest a barrel even though the remaining whiskey never left the barrel? And one that came to mind just now, are there fill requirements on barrels? Wouldn't a half-filled barrel behave slightly different than a full one?

These were all really hypothetical questions regarding formula approval requirements. Also, corn whiskey doesn't have to touch cooperage at all or require a formula. There are several brands out there of a 'white' corn whiskey that state specifically that.

Hi all, 

Fairly green distiller here with an hypothetical that I thought of while trying to wrap my head around some of the TTBs regulations regarding formula requirements.

Say I develop a mash bill of 80% corn, 10% malted barley, and 10% rye. Say I distill in twice (not that important) and the proof at distillation is 150. What would I designate the distillate? Would I designate it as the general class 'whiskey'? Or would I designate it as corn whiskey since it fits the S.O.I.? 

Now follow close. Say I wanted to use that distillate both for a white corn whiskey as well as a bourbon. Could I use a singular batch for both? What then would I call the distillate? Would I need formula approval since I would have to designate it as one spirit (whiskey or corn whiskey) then change it's class/type to another (bourbon) even though bourbon does not require a formula approval normally? 

Now focusing on a singular barrel of that sweet, sweet bourbon. Say I partially-harvest an amount in 1 year for a small bottling. Would the aging clock stop even though the whiskey leftover never left the barrel? Or could I age it longer than 2 years and get the Straight Bourbon designation? If I am able to, how does that affect formula requirements? All three of those products normally don't require a formula and I'm in no way using weird techniques in production. Would I still need a formula approval for at least 2?

3 hours ago, bluestar said:

Yes, but that is a subjective evaluation. NOTE: it does NOT say NO character, aroma, taste or color. It does not say "detectable". What does "distinctive" mean? It could mean, so as to distinguish one vodka from another. But clearly you can do that even with supposedly totally neutral products. So, yes, you could be found NOT to be a vodka by violating this, but since it is not quantitative, etc. On the other hand, being of 190 proof and some degree of filtration CLEARLY are requirements of vodka. And the change of type requires formula, regardless.

Except the TTB doesn't say filtration is a requirement. I don't mean to step on any toes and I have no doubt you know way more about regulations than me, but I have yet to see anywhere where the TTB requires filtration for it to be considered vodka. I vaguely understand the formula requirement, since you could argue you are changing it's classification from 'no type' to 'type: vodka' (as I understand it) but still don't see why it is needed if you are merely diluting.

Sorry for being a pain. I am still fairly green but have come to realize a lot of the TTB regulations are structured poorly (IMO). Thank you everyone for being patient in explaining the reasons behind some of them. I have another hypothetical but I think I'll make a new thread for that one. 

1 hour ago, Jedd Haas said:

TTB made some changes to formula requirements in their 2016-3 circular, which can be downloaded here:

https://www.ttb.gov/formulation/do-I-need-a-formula.shtml

In short, TTB approved "general use formulas" for certain common types of spirits, including vodka. Meaning a formula is not needed. See the circular for the exact language; there was also a thread that touched on this when the ruling came out.

 

That was where I read that you need to 'do something' to NGS to turn it into vodka. I can slightly understand what Dunbar and Bluestar are both getting at for formula approval, it just doesn't make sense and seems convoluted to me. I also think you should still be able to argue that designating a type-less spirit (NGS is a class, not a type) to one of its types (Vodka) isn't changing its class (still under NGS) or type (it didn't have a type to start with). 

Here's the hypothetical I think of. I have just ran a distillation run producing near azeotrope. It was distilled to have no distinctive color, aroma, etc. This distillate fits the S.O.I. of two things. The class NGS and the sub-class (or type) Vodka. Whether I name it one or the other should not prevent me from considering the distillate as both. Same goes for if I sourced that NGS through another company. It's a waste of time and tax-payer dollars to have a TTB officer look at a formula approval for changing NGS (made to vodka specifications) to vodka IMO.

22 hours ago, indyspirits said:

If a rectifier charges the still at say... 50% ABV and redistills to 95% how are they changing the classification? Is it the act of dilution? What if they simple reduce to 50% and filter without re-rectifying? Clearly this is now getting a bit far afield from the OP but I feel closely enough related so I shouldnt be labels a thread hijacker (although apologies to the OP regardless).  

This thread has derailed from the OP a long time ago. 

That being said, I'm also curious about this because I have seen a few times you need formula approval for vodka made from sourced NGS. I've also heard that you need to redistill or treat NGS with charcoal or some other material to change it to vodka. However, the way I look at it the TTB states NGS is a class and vodka is a specific type of NGS that is:

Neutral spirits distilled or treated after distillation with charcoal or other materials so as to be without distinctive character, aroma, taste or color.

So could you not just dilute to target proof and argue that the NGS you sourced was distilled so as to be without distinctive aroma, color, etc.? Then you would just be designating your NGS as vodka rather than the other type, 'Grain Spirits'. You wouldn't be changing class or type so no formula would be needed. 

Another way I look at it is when you make whiskey. When it comes off the still it is the general class 'whiskey'. What you do with your distillate will dictate what type it falls under. Whether it be Straight Bourbon or mere corn whiskey. Neither of those require formula because you're not changing the class or type, merely designating it to a type. 

The two examples seem to be identical. If someone with much more knowledge can show me how I am wrong, in a way that is easy to understand, please do so because this is something I've struggled to wrap my head around. 

Side not: While I'm not a fan of NGS sourced vodka, I've been in operations that do it. I feel like redistilling it so you can put 'Distilled by:' on the bottle is more misleading than simple dilution and filtering with a subsequent statement of 'Produced by:'. I have more opinions on it and am open to further discussion.

On 7/31/2018 at 8:48 AM, indyspirits said:

 Riddle me this batman... if a consumer buys a bottle of 45% ABV that was bottled at 100F and then takes it skiing (ignore the impracticalities of the premise) where it's 10F will the fill be out of spec? More rhetorical than anything. 

 

 

If you bottle by mass then you would still be in spec. In the TTB document SSD:TM:516 @meerkat posted the example just measures volume and applies a correction factor based on proof and temperature of the sample. Whether the sample is at 100F or 10F, the correction factor should change observed volume into a standard volume close to 750 hopefully.

I've had really good experience with Golden Barrel molasses. Very flavorful and their blackstrap is usually on the higher end of their stated sugar range.