Barrel with Polycarbonate Heads - TTB Bourbon Designation

[barristerandbrewer]

Hi All,

We recently had a visit from a TTB agent, and he brought a specialist from the formula division with him. They were extremely pleasant, professional and helpful. 

During the tour of our facility they were very interested in an "exhibit" barrel we have in our rick house where we do part of our public facing tours.  The barrel is a regular 53 gallon barrel, new charred oak, from West Virginia Great Barrel Company.  However, rather than oak heads, the heads are big polycarbonate plastic disks.  This is a cool exhibit to show angel's share, and it lets the visitors see the inner surface char.  The formula specialist immediately questioned whether the product inside could be sold as "bourbon whiskey" because the entire container wasn't made of oak - only a part of it. I've attached a picture of how it looked right after we filled it. 

The bottom line for us is that this is one barrel out of hundreds, and if we can't use the contents for anything but cocktails (after paying the appropriate FET of course!), it isn't the end of the world.  That said, it would be nice not to have to segregate it out and use it a certain way.  We plan to do another one of these at some point, and polish up the heads and use them for another exhibition barrel.  

The TTB folks weren't sure themselves, but I'm wondering if any of you had run into this issue before?  If so, did you get a definitive ruling from TTB on it? If I hear anything back from them, I'll let you all know as well.

Thank you,

Blitz

[JNorris]

I have had discussions with the TTB about oak containers that are not 100% oak like standard barrels are.  I even took them by a booth at a convention to ask if this should be considered a barrel/oak container per their definitions.  I did get an answer from them but nothing in writing.

If you would like an answer for yourself, and the agents who visited you will not give you one, I would advise to contact rulings and regulations and ask the question via email.  I would also supply the picture as well.  This way you have the answer supplied to you from the source.

[FIVE x 5 Consulting]

My two cents: If this is an acceptable aging vessel for Bourbon, then wouldn't a Squarrel be, too?  And I think we've established that Squarrel barrels do not qualify.  It's not an "oak container" as regs require.  It's a container made of oak and "other stuff".  

I second JNorris' suggestion to reach out to RRD for an answer you can take to the bank. That said, I have never successfully gotten a response from RRD on queries like this (trying since 2018)...