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KRS last won the day on December 31 2017

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  1. Allelujah! I was considering defiant action, but reason prevails on both sides! Additionally, although the possibility of illicit use by those in desperate need of an alcoholic beverage, the issue of children accidentally ingesting it made me cough. I used to work in a profession where contact with the Poison Control Center was on speed dial. Since children have been known to wilfully ingest Drano, what could we possibly do to ethyl alcohol to top that for an unpleasant taste deterrent ?
  2. Hello. The standard for Bourbon requires two years in a new oak barrel minimum. I'm surprised that you were surprised that an age statement was required for your label. Further, the idea that whiskey has to be 48 months old, is totally refuted by the standard for Bourbon. I did not see a requirement for an age statement on any other whiskey besides "straight" whiskies. Where in the standards does it say whiskey has to be 48 months old or it needs an age statement? I don't mean this to sound contentious, it's a real question. I understood the long, rambling document to perseverate on the issue of age statements being true. I can understand your chagrin that there are craft distilleries that lie about one thing and another, but not having an age statement is not the same as lying. If the underlying frustration is with accelerated aging techniques like oak chips and oxygenation not having to be disclosed, then, perhaps that's the better comment to affect policy. Whether or not the TTB devotes its budget to seeking out the perpetrators of false or obfuscated labels, doesn't release all of us from being truthful. The world is full of people who cheat, so let your integrity speak for itself. If the product has a mixture of aged spirits, the age statement has to use the youngest aged spirit as the length of time. Age statements make little sense in terms of quality of product when you consider size of barrel and the effect on maturation. However, it does make a difference to some consumers if there is an age statement. I see no reason not to use age statements if the distiller considers age an important element in the quality of their product. Consumers who do care will pay attention. Honestly, I see it as a big-endians/little-endians (Jonathan Swift) sort of problem.
  3. Is anyone working with a distributor who only fills orders based on the distillery's contact with retailers? The distillery doesn't place the order with the distributor, but lets the distributor know exactly what the retailer wants. The distributor contacts the retailer to confirm the order and asks for a purchase order. The distributor does not have sales people and does not solicit sales for the distillery. The distillery delivers the product to the distribution warehouse, and is responsible for setting up the delivery to the retailer by a third party from the warehouse. The distributor pays the delivery service. The distributor receives payment for their invoice to the retailer, pays the distillery from the money received from the retailer, having factored in the cost of delivery. The distributor payment is static per case, but varies because of delivery charges. This appears to meet all 3-tier requirements, but I have been told that the California ABC has issues with this. Does anyone see any flaws in this arrangement? It seems like a legal opportunity for micro-distilleries to have a better chance to succeed, given the small volume of production. The idea that small distilleries could possibly dictate terms to retailers, and interfere with their ability to do business with other manufacturers, is ludicrous.
  4. KRS

    Contract Production

    I apologize, but I haven't figured out how to respond to posts separately. I feel dumb saying so, but there it is. DHDUNBAR: Thank you for answering. It's a local bar, and as far as I know they would like me to bottle my gin with their label. It may be that they want their own recipe, but when they asked me about it some time back, it was about my gin with their label. I will find an an attorney for this. We will require a commitment by the batch and one month's lead time, make that 6 weeks. I like to rest the gin for a month. Maybe that's unrealistic for contract production... TNDISTILLING: Thank you, too, for answering. I will build the FET into the price, which is what we did when we distilled and bottled a liqueur recipe that belonged to the customer. I can see that it's a good practice to put the tax money aside, but we just pay the excise tax on everything we take out of bond during the quarter. As far as R&D, well, they're not able to create a recipe. I'm hoping that bottling my gin under their label is all I'll have to do. If that's what they want, that's what they'll get, it's what they asked for and it's up to them to sell it. I imagine that they'll cough if they want their own recipe when they find out how much I'd be charging for R&D. I'm aware that private labels don't need to be submitted if they're special events, but I don't know about labeling contract spirits. It would be nice to find out that it's the same as long as what's in the bottle is the same. In any case they'll pay for their own label design and we'll get them printed. We'll charge them for label printing, bottles, corks, sleeves. We'll charge them for recipe ingredients, federal taxes and some labor cost factored in, by the proof gallon. The distributor will add a cost, of course. They'll need to have a contract with the distributor as well as with us. Payment will be upon receipt from our distributor. I really appreciate your advice. Thank you. Karen
  5. Hi! I'm not a new distiller, but I would be a beginner at contract production. They want my gin under their label, but I'd like to hear from anyone about drawbacks to that arrangement. Please let me hear from you about recipe ownership considerations specifically. Then, I'll be wanting to know about the best legal procedures and who is recommended. Thank you.
  6. Hi. Thanks for thinking about this. Yes, I use GNS, and I'll check with them about variations in source. I buy it from the manufacturer. I did use coriander from a different source, which was more pungent. That could indicate heat, I think. However, time and air have made a major good effect on the gin. I drank some today that had been resting in the tank an additional week: heat was balanced and flavor/aroma were what I'd wanted. I can't bottle till next week, soonest, maybe week after that, so I'll chill out and expect to be pleased. Thank you again.
  7. Minor details, right? It's gin, 86 proof. It's a second batch of a recipe that was terrific the first time, also 86 proof. That batch was very, very smooth. I'm very disappointed in this new one. A few of the botanicals were from a different source, but I doubt it's the issue. I made it January 12, Carter Head gin basket. I don't want to bottle but I'm being pressured for commercial reasons. I'm hoping that resting until March might solve the problem. Batch one rested for two months, and I definitely thought it improved from its early days. I hope there's hope!
  8. HI, I've been doing "other" things, so I just got your post. I agree that not polluting the planet is something we all need to consider, and keep it in mind when we're doing whatever. The TTB and FDA have statements relative to final product and initial source. I think there's a great deal of investment by those who use strictly organically produced original sources, and they deserve respect for their efforts. The issue is one of misleading consumers by the implication that organic source leads to a product that is materially different in its final form as an alcoholic spirit. There is no evidence to support that, and at this point, it is a belief. There is often a great deal of passionate defense of belief in just about anything. I'm not debating your belief, it's not a reliable method for promoting a factual approach or bringing people to focus on what we do have in common.
  9. I'm very dissatisfied with my latest production. What causes some runs to produce excessive heat on the palate? Solutions?
  10. Tom, you are saying nothing but the truth about using organic certified raw materials as better for our Earth. I am not indifferent to the concerns. I wonder if it ever will return to the type of farming that was the norm for thousands of years of agricultural production. I do know that famine was much more prevalent in days gone by when crops could not be protected from pest invasions. The Irish potato famine and horrendous loss of life in the 19th century comes to mind. Drought is probably the greatest cause of famine. Field irrigation, of course, existed since agriculture began, probably. Pure, clean water was not necessarily the source used. I do believe there is more widespread harm done from artificial fertilizer run-off in the water system. Despite legitimate concerns about pesticides used in agriculture, I believe it is our biggest threat to long term public health, followed by the methane released by commercially raised food source animals. In the meantime, we can only hope that more benign, equally effective methods will "invade" commercial practices. This does not say that I believe using the term organic on a bottle of spirits ought to be used without qualification. Apparently the TTB requires an explanation somewhere on the label. I read the info on the links you provided. Presently, the TTB regulations and labeling seem to require legal certification for using "organic" on a label. In the case of distilled spirits, it seems the use of 100% organic requires the spirit producer to receive products from or be a certified organic source. Otherwise, "produced with organic ingredients" is allowed if at least 70% of the spirit is produced with organic ingredients. I was uncertain--TTB regulations being as opaque as they are, if the label has to say "produced from 70% organic materials." In any case, the label has to have legal certification of the source on the label. Also, the TTB has ruled that there is no difference in the effects of GMO grains on health than any other agricultural products, but again, it was unclear to me if that meant non-GMO was permitted without legal certification.
  11. Regarding "organic spirits," how about "Distilled from organically grown barley/corn/wheat/rye/whatever?" It's honest and not misleading. Regarding the gluten free concerns, there is no gluten left in a beverage that is 80 proof or higher; lower proof, don't know. Basic science is not the common understanding at this time, facts being supplanted by beliefs and feelings. I have a cut-out of a Bizarro Sunday comic strip on my fridge. A TV newscaster is predicting the path of a severe hurricane, and telling people to batten down their homes and leave the area. His ending remarks: "...for you people who don't trust the media (i.e., including scientific facts expressed through media, implied), just stay put." Lots of scientific studies validate the following: beliefs are not rational, the feelings they engender narrow perception to accommodate belief. Beliefs can only be argued; facts can be discussed. So, please, stop the fruitless arguing, Dr. Karen says..and you can believe her!K
  12. It isn't legal? I believe I've seen it. Maybe I'm confusing it with wine. I'll check. When you do change your labels, consider the honesty of adding the fact that there's no difference between s made from organic ingredients and spirits not made from organic ingredients.
  13. Irradiation is done with microwaves. The definition of organic is not the issue. The issue is labeling a bottle of spirits "organic." The spirit is not organic--the ingredients used to make it were produced with organic methods. The resulting spirit is not superior to a spirit produced with non-organic ingredients. Irradiation, "organic spirits," etc, are misleading in terms of the benefits or detriments. Because people want it, doesn't make the customer right. Ignorance is just as endemic as alternative facts--undoubtedly linked to each other. Additionally, many farmers produce "pesticide free," which means exactly that, but don't go through the difficult process of getting their "organic" designation. Are the farms in their vicinity spraying madly, spewing into the atmosphere where they infiltrate the "pesticide free" crops? Possibly. I do think making the effort to produce crops and raise livestock in ways that limit the detriment to our earth is admirable. I don't think those who make the effort have the right to imply that it's a superior method that results in a superior product when it's not. People are being tricked into believing that they are getting a benefit from the product itself, not that purchasing the product is one more for Mother Earth although not intrinsically different from any other spirit they could have bought. I do believe I'm getting too annoyed about the fact that the central issue has not been addressed by the distillers that use organically produced ingredients.
  14. Pete B: A preference for alternative facts seems to becoming endemic. We need truth in advertising beyond the dangers of alcohol on our bottles. Implied benefits need to be clarified.
  15. When I read your response, I did think there was some condescension in the tone, but I can see how you might think I owe you one for calling organic spirits a “marketing ploy.” Sane people all care about the earth and what we’re doing to it. I count myself among them. The methane from livestock production is one of the biggest causes of global warming, which indicates the benefits to Mother Earth of a vegetarian-heavy diet. Which then brings with it the issue of pesticides. That’s a hard one. The government has declared that what is used commercially at this time leaves only harmless residue, which might be true, considering how many Americans eat non-organic crops and live to a hearty age. It’s not true for field workers, however, unless their employers follow strict guidelines for crop spraying. Not enough do, as I can attest. I was an infant development specialist who worked with many developmentally disabled children born to field workers. I wouldn’t eat Fresh and Easy produce, grown in the area where I worked, unless death was imminent and I was hungry. Irradiation of food does not make food radioactive any more than we are left radioactive by dental x-rays. There is no credible research that indicates a molecular change in human beings or animals that consume GMO crops, and I don’t merely reference government findings. Further, the use of irradiation in no way relieves food producers of the obligation to follow strict sanitation standards, although, as with most regulations, some people don’t. Putting them out of business is a worthwhile endeavor. Finally, GMOs. I’m sure you know that gene modification therapy has helped a great many human beings avoid or recover from debilitating conditions. If it’s okay for them, it’s okay for field crops and the people and animals that consume them. What I want is truth in advertising from spirit producers who label their products “organic.” A disclaimer would be honest—and we all care about being considered honest, don’t we? “The organic raw materials that were used to manufacture this spirit beverage have no more effect on the spirit produced than non-organic raw materials.”
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