kkbodine

2 hours ago, Glenlyon said:

I would also add: Keep your labels simple yet elegant. Go to a liquor store and spend some time just looking at the over all the products. Look wide, look close up. You'll soon notice a few labels stand out. These are more than likely, the big brands you are used to. You'll also notice that these labels are all very classic and they never change. So choose you labels carefully, you may be using them for a very long time. Also, your labels define your brand and so all other marketing & advertising and corporate image all have to interconnect to give your brand a unified and professional feel. (Even if you have to bootstrap a lot of it.)

You have made some great suggestions. I would also add, can you tell what the product/distillery is from a distance, say across a bar or room? Simple design seems to stand out better.

2 hours ago, needmorstuff said:

I love Tito's story... but are you saying their vodka is made with GNS? if so i just died a little bit inside.

From some early video coverage of Tito's it seemed very clear that they used GNS. I have not been inside their facility to see for myself.

55 minutes ago, kleclerc77 said:

I was wondering the same thing. We intend to give ours away to places that need it, and I thought that was the whole intention. I've seen a number of places selling it or starting GoFundMes, possibly as a way around selling it. Obviously there is a production cost on all our ends, but selling this stuff seems totally against the point.

In my state of Maine it is estimated that the hospitals and healthcare facilities need 400-500 gallons of sanitizer per day. They are expecting the local distillers to supply that amount for free; for how long who knows. Obviously not a sustainable model.

17 hours ago, dhdunbar said:

 

Your observation that no one from TTB has complained sums things up.  They don't have time to look.  They can't possibly audit them for irregularities.  If you are not doing it correctly, it is unlikely to have a consequence.  Further, the reports are not evidence of compliance.  Everyone is concerned about them, because they, tax returns, formulas, and labels are likely the only contact most of you will ever have with TTB.  My business is not exactly drowning in requests for help in responding to TTB's allegations of violations :-).  Because the reports prove nothing, I'd not be nearly as concerned, from a compliance standpoint, with them, as with the records from which you gather the information.  How many persons who are making gin by redistillation in the processing account are keeping the redistillation record required by §19.602.  How many have the package records?  Who is keeping serially number gauge records?  Those are the records that demonstrate compliance.  But who is looking at them?  

So, when someone asks a question, I give a by the book answer, to the best of my ability.  That what you are doing doesn't comport to what I think you should be doing, based on the regulations, which I usually try to cite by number, is likely never to become an issue, even if my reading of them is spot on, or even if you have no records, because TTB is not likely to knock on your door and if it does, it is more likely than not gong to take punitive action unless it finds you have not paid the taxes that are due or are bottling far more rye than your records can support.. .  

In fact, I think most TTB employees do not know what the regulations require.  That sounds harsh, but it s not unusual.  I should know that better than most TTB employee, amnd so should you, because we deal with it every day, whereas they might see one or two distilleries a year, if that. 

I appreciate the response. I have had three visits from the ATF/TTB in 28 years at various wineries/distilleries. First visit was to show the new guys what a winery looks like just in case they ever got sent to one. Second visit was trying to iron out some licensing issues during the application process. Third was an inspection, and I was able to supply all of the backup records requested. I was kind of surprised about what was looked at and what was not, though it was only a 2-3 hour look  In my opinion, the regulations and forms don't capture how a modern distillery (or winery) operates and make it harder for the TTB to do its job. I doubt anyone is going to re-write the whole thing from the start anytime soon.

20 hours ago, dhdunbar said:

Let me think about that. 

The problem with using line 20 is that an entry there removes the spirits from the bulk processing account.  If they are removed, they have to be in one of the other accounts, either production or storage.  Storage makes no sense, because you don't redistill in storage.  So, they would have to be in the production account.  But spirits returned to the production account for redistillation are captured in line 17.  Entering them into both line 20 and line 17 would double the quantity removed.  That can't be correct. 

 

I missed line 17 and may or may not be doing all of this on another form currently. Certainly no one from TTB has complained or maybe no one ever looks.  On another note, it seems like having three forms is overkill. Wine production makes do with one just fine though it can get complicated too.

15 hours ago, dhdunbar said:

Now, whether you receive them into the storage account or the processing account, if you resdistill them to make vodka (NSG is a class, vodka is a type within the class, so a change from GNS to vodka is a change of class and type under TTB's rules) or make gin or some other product that you flavor by evaporation in redistillation, you do that in the processing account (§19.602), not the production account.   The only reason you would return spirits to the production account for redistillation is your desire to salvage alcohol which you have somehow screwed up.  That redistillation is done under §19.314 and following.  

So the re-distillation would be reported on the Processing report line 20, used for redistillation? 

2 hours ago, Southernhighlander said:

We have a pot still at a distillery in VA that puts out 75 gallons per hour of whiskey.  Has anyone seen any other pot stills that fast?

In person yes, but only the huge ones at Jameson in Midleton Ireland. I'm intrigued by your current offerings and vacuum setups, impressive.

19 hours ago, FijiSpirits said:

Illegal where?  There is a whole planet worth of freedom outside the USA. Further, this is a third party’s video about their product. 

 

Try to relax a bit. Life will suck less. 

Dude in the video is in Texas as far as I can tell, and they are actively using his videos for promotion. There are so many of us trying our best to follow all of the often bizarre layers of regulations, while there are plenty of others doing whatever they want. I get at least one admitted home distiller a week in my distillery tasting room. I'm actually somewhat neutral on home distilling and I'm plenty relaxed, thanks.

On 7/2/2019 at 3:22 AM, cezary said:

Please look at  George intro-don't forget to subscribe

 

Cool still but you seem to be promoting illegal home distilling...

I actually got so tired of endless pressing at one distillery that I did exactly this. We stopped pressing apple mash and just fermented as is. As fermentation ended, we drained as much liquid as possible to be distilled and composted the remains. Apples at the time were about $0.05 per pound. We saved 100's of man hours and quality was at least as good a when we pressed.

7 minutes ago, Silk City Distillers said:

New or used oak?

Good question; used in my case. Sometimes used American oak ex-bourbon barrels, and sometimes used red wine barrels (French oak) from our winery.

In my location with my single malt whiskey, I see five years as the minimum but we are bottling it at seven. But I greatly prefer longer aging times (taste wise) and have only tasted one small barrel aged product that I personally enjoyed (out of maybe 75).

4 minutes ago, klattig said:

Tom, we don't use a hydrometer for OG or FG - we use a refractometer.  Does your comment also apply to brix readings obtained with a refractometer?  I'm under the impression that longer glucose chains (dextrins) will impact the refractometer, but not so much 'other compounds'.  Thoughts?

You can't correctly measure final gravity with a refractometer; the alcohol distorts the reading. Assuming you mean the reading after fermentation.

8 hours ago, whiskeytango said:

Im probably wrong but I dont see much different in bottling between 45 and 47 I still think the same issues will arise at a higher proof.  As far as filters does osha really monitor what filters you buy and use?  

DE (Diatomaceous Earth) has potential health consequences.

On 7/4/2018 at 6:36 PM, dhdunbar said:

You are correct.  The standard for the  "whiskey distilled from " designations does not require storage at 125 or less.  Used containers, yes, but not 125 or less.

I broke my own rule.  I didn't look before leaping.  I just spouted from memory.  That is a dangerous practice.

Thanks

 

Thanks for your detailed explanation. 

Interesting discussion and very relevant to a label I'm working on and about to submit. One point  @dhdunbar "My take on this (and it is mine, not TTB's) is that  a whiskey distilled from 51% or more of malt at 160 proof or less, stored in used oak containers at 125 proof or less, and bottled at not less than 80 proof, is, under the standards of 5.22(b)(2)  "Whiskey Distilled From Malt Mash."  The class is whiskey, the type is whiskey distilled from malt mash."

Looking at CFR 5.22  I don't see where it says "stored in used oak containers at 125 proof or less". It certainly says that for other types but not specially in the section defining whisky from X mash.

"(2) “Whisky distilled from bourbon (rye, wheat, malt, or rye malt) mash” is whisky produced in the United States at not exceeding 160° proof from a fermented mash of not less than 51 percent corn, rye, wheat, malted barley, or malted rye grain, respectively, and stored in used oak containers; and also includes mixtures of such whiskies of the same type. Whisky conforming to the standard of identity for corn whisky must be designated corn whisky."

Is there another relevant section?

Yesterday I was working on the bottling line and wondering aloud about aging on a boat and Jefferson's in particular. It seems to be a clear violation of the regulation cited... I'm not sure if I'm over it or not. Edited to add: Anyone out there have a copy of one of Jefferson's ocean aged COLA's? My searching produced nothing but maybe I'm just lousy at searching today.

Another edit: I found one of their COLA's and it shed no light on the topic other than being "bottled by"

They will take samples and send them to their lab.

27 minutes ago, johnbsys said:

"...The packaged column is for something else. Look at package under the glossary of terms."

Are you saying that I should not use the 'PACKAGED' column at all?  So for on line 28 instead of putting the PG of what I cased under PACKAGED and left over bottles PG under BOTTLED I should just put it all under BOTTLED?

 

Thanks,

 

John

If you are bottling into actual bottles you should be using the bottled column. So yes it should all go together under "bottled". It is all about proof gallons; case/bottles should be added up appropriately and translated into PG.

You have made this way more complicated than it is. The proof gallons bottled should have gone on line 9 and line 28 co. b the first month. This report is all about proof gallons, case/bottles don't matter really. In succeeding months, the bottled inventory carries forward on the part II side of the form. As new products are bottled their proof gallons get added to part II from part I and usually you will have nothing left on line 26. As products are removed from bond, line 33 col. b  most likely, their proof gallons are subtracted. In my opinion, you should re-submit the first report correctly as an amended report, top right of form. Then onwards from there. Message me if you want.

On 2/11/2018 at 1:54 PM, Silk City Distillers said:

27 CFR 5.40

Thanks for that.

18 hours ago, PeteB said:

That is the page I was looking at. 

I assume BAM is the equivalent of "Fake News" 

Note the "2" on "Whisky"

According to that note at the end of the chart:

"²Sufficient as class and type designation ONLY for whiskies made by: --Blending two or more specific types of whiskies, e.g., a blend of rye whisky and corn whisky should be designated “Whisky” OR --Treating with harmless coloring, flavoring or blending materials* a specific type of whisky not customarily so treated, e.g., bourbon whisky treated with caramel should be designated “Whisky”"

So if we assume the TTB is following this as a labeling guideline (and a distiller is following this rule), using the word "Whisky" as the class/type of product is limited in a way but also opens up some potentially interesting whisky varieties and treatments (for those so inclined).

Coming back to age, the BAM is very clear. The actual underlying regulations I can find aren't clear though I would assume that the TTB would follow the BAM guidelines because they have created them as a guide for labeling. Anyone know where in the CFR it says anything about whisky aging 4 years? I'm guessing it is carefully hidden.

58 minutes ago, Georgeous said:

why not? I just spoke with ttb and they told me if I poured through a trough from one vessel to another it has touched oak and I can put an age statement on it. She recommended aged less than 1 minute. So what would be different of a trough or a stave for that matter? Hell what about an oak stir stick my wife calls a mop handle?
 

That answer from the TTB makes no sense and seems like a very loose interpretation of the word "aging".

3 hours ago, Krookid Leyk Distilling said:

 

 

We are looking for a young and energetic individual that is willing to work with and take control of the production process. 

 

 

Looking to get hit with an age discrimination lawsuit?

21 hours ago, Roger said:

The wine industry is very strict about viticulture, fortification origin, etc and the beer industry is all local, but unfortunately Big Alcohol has embraced laws that obfuscate the actual origin of spirits to the detriment of the true craft / local centric culture.  

The wine industry has stressed local and terroir, or at least called out product origin, for a long time; with limited ways to obfuscate. Beer has been getting a pass on using local. The beer industry is a way behind in sourcing local ingredients and most "craft" brewers use nothing local; it simply has not been an issue. The resurgence in local hops seems more driven by market opportunity for farmers than any real call by beer consumers. Owning both a winery and a distillery I see a vast range of consumers. People who know anything about the business or understand the information on a label are few and far between so it is a constant educational process. Most days it comes down to taste and price; local is a nice to have for some people, most don't care. A frustrating reality to those that do care. The local food movement is very strong in my area and a few other areas of the US so some of that is spilling interest over.  I actively encourage people to read and understand labels; though servers in tasting rooms can get away with all kinds of lies without repercussions. Of course one can also walk into any place that sells alcohol and find labels that the TTB should never have approved.