DBlakely

Thanks Roger! Sounds like a plan. Doesn't simple piece of art actually be my final logo?

No worries! I completely understand what you are saying. I am new to the industry and don't want to do anything from ignorance. It was my understanding exactly what you stated, then I signed up for Whiskey Systems and the trainer (who has been in the compliance portion of our industry for many years) stated if we aged our rum, we would need a formula. I was confused so I was on the hunt for approval by the TTB since its their rules. I submitted the question to the TTB and they replied I would need a formula; however, I can't find anything supporting the response so I thought I would bring it to ADI for guidance. The last thing we need is some kind of fine because we didn't play by the rules. Can you see my frustration? What will happen if I don't get a formula and later it is determined I was to submit a formula? I am currently asking for permission rather than forgiveness.

Thanks Roger! We are currently working on our marketing so we aren't ready to obtain COLA. What has been produced has been put in a stainless steel barrel. As we wait, I wanted to add the silver/white rum to a new and/or used oak barrel and then sell as Aged Rum. I understand this will require a different COLA than the silver rum. My challenge is I am looking for confirmation if the aged rum needs a formula. We will not be adding any coloring (although I appreciate your idea about adding a little before bottling. I have heard of that before). The only alteration to the silver rum will be the harmless coloring from the new and/or used oak barrels. From everything I can find, spirits aged in new and/or used oak barrels do not need a formula but when I asked the TTB they stated a formula was required. I have no problem submitting one but other than stating I am adding harmless coloring from the barrel, I am not altering the product. Make sense?

Which is????

My apologies. Yes. We use pure cane sugar and/or panela, molasses, yeast, water.

Because we are using yeast? When we applied for permit, the recipe we reported had listed yeast as an ingredient and our permit was issued.

It is purely rum. Sugar, molasses, water and yeast. The question I asked the TTB was: Does aging rum in a new and/or used oak barrel require a formula? The information provided isn't specific. How will I know if the coloring from the barrel exceeds a total of 2.5 percent by volume of the finished product if I am to get approval first? Their reply: Currently a formula is required and the product reclassed. Please submit a formula. The latest ruling I could find was from 9/16: The Alcohol and Tobacco Tax and Trade Bureau is approving general-use formulas for certain distilled spirits products subject to the formula requirements in 27 CFR 5.26, 5.27, and 19.348. Proprietors of distilled spirits plants producing vodka, whisky, brandy or rum with the harmless coloring, flavoring, or blending materials specified in this ruling, in accordance with these general-use formulas, do not need to submit a formula to TTB for approval. It is my understanding that harmless coloring, flavoring from a new and/or used oak barrel doesn't need a formula but I wanted to be safe so I sent a message to TTB. I am confused.

We are using RO to cut; however, the rum is cloudy still. Thoughts?

I finally received a response from the TTB. I am not sure why a formula is required for rum when it isn't required for whiskey/bourbon. Currently a formula is required and the product reclassed. Please submit a formula.

Thanks! I understood the flavor added but not the harmless coloring. I know the barrel will color the rum but have no idea what %.

I have attempted several times to get confirmation from the TTB to no avail so I am hoping you can assist. I have started a rum distillery. We are not ready to bottle so thought we would put in new and/or used oak barrels; however, I don't know if we need to get formula approval. The rules state formula approval is required before production. The rules state Formulas for rum are only required if harmless coloring doesn't exceed a total of 2 1/2 percent by volume of the finished product. How will I know if it exceeds if I can't put in the barrel first. Your insights would be greatly appreciated! D

Were you able to sell everything?