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.