I am going around and around with the 'specialists' at the TTB... They are saying my 'Brand Name' for a Class-Type 414 Florida Gold Rum cannot be 'Palmer's Tropical'... (keep in mind I have 5 COLA's approved with just that, we just want to update the labels to a new front and back label..)
First they wanted it to have a formula to explain 'tropical'...
After stating the steps and results from the "Do I need a formula?" for Rum, they backed off of that and came back with 'Tropical is misleading' as it is not the name of our distillery. (do they understand what a brand name is?)
I tried to explain that it was just a Brand Name, but they were not having it... They said I was misleading the customer because I did not show the relationship between Cotherman Distilling Company, listed as the distiller and bottler on the back, and 'Palmer's Tropical' on the front... So I sent them the COLA approval for Weller, which says Weller on the front as the Brand Name, and if you look at the approval details, "Weller" listed in Part 1, line 6 as ... yes... the "Brand Name"...
They are saying: "the name Palmer Tropical is misleading because Palmer's Tropical is not the bottler for this product and does not appear on your permit. The words "Bottled For" must precede the brand name on front label so that the consumer is not misled by the true bottler."
I am biting my tongue.... It is a Brand Name, Dammit! I just wish I tried this a few months ago before the survey they sent expired... boy they will get an earful next year!!!!!
In the background, from the beginning, I submitted a formula for 'Tropical' Rum using at least 51% molasses from south Florida, defined as having a 'Tropical' climate, and mentioned in the method of manufacture 'distill to a spirit that retains 'Tropical' flavors of Rum... It was approved in a few days, and I resubmitted new application and attached the formula...