Unaged grape distillate Type. Immature Brandy/Brandy/Distilled Grape Spirits?

[Longdogs]

We are applying for our first cola on an unaged grape distillate.  I tried to get it approved with the wording "Unaged Brandy", but it was rejected as an incorrect format for an age statement.  It never touches oak, and that leaves me with questions.  Does that make it just "brandy" since it doesn't conform to any of the 9 types?  I see multiple other labels list it as "immature brandy", but the way I understand it immature brandy has to touch oak, just less than 2 years.  I also see Remy V label lists theirs as 100% Distilled Grape Spirits.  I don't follow what class that would be unless they distilled it out over 160 proof?  It shouldn't have any age statement at all if it never touches oak right?  Any ideas what this product should be called?

Thanks

[Tom Lenerz]

Was it aged less than 2 years or more than 2 years in oak? If less than 2 (0 is less than 2) its immature, if its over 2 then its brandy.

[Jedd Haas]

In general, all spirits distilled from fruit are brandy. However, there is a specific rule for grape brandy: it must be aged for a minimum of two (2) years in oak to be called brandy. Any less than that and it will be immature brandy.

Since your brandy is distilled from grapes, and is aged less than two years, it is immature brandy. Try again with that term as the class and type.

In the case of Remy, they may have distilled it to neutrality.

Additionally, if you look at the Production report, you'll also see that brandy has two options: either below 170° or above 170°. 

 

 

[Longdogs]

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."