We resubmitted after we dropped the "unaged" from the label, leaving just "brandy", but before I asked the question on here. It was approved as "Other Domestic Grape Brandy". I called to make sure there wasn't going to be an issue. The guy at the TTB explained that Immature is aged on Oak under 2 years and that our product not being aged at all does not fall under that criteria, but falls back as "brandy" due to it not falling into any of the 8 sub types. Its definitely possible that other agents would disagree, but we are going with his explanation and approval.
"Brandy, or mixtures thereof, not conforming to any of the standards in paragraphs (d) (1) through (8) of this section shall be designated as ‘‘brandy’’, and such designation shall be immediately followed by a truthful and adequate statement of composi- tion."