Substitute for Borage Flowers?

[AU Golden]

We just submitted a gin recipe with borage in it to the TTB, and got a very hard no.  Apparently despite being a food that's regularly consumed, it's not on the GRAS list. Anybody here have ideas on good substitutes that still give that sort of floral cucumber characteristic? We originally tried borage due to loads of suggestions on distilling forums, so I'm sort of at a loss on where to go from here. Thanks for any suggestions you might have.

[Kindred Spirits]

Sorry to hear that you are running into this issue. 

I have had a number of clients deal with the same problem. Using ingredients commonly used in the food industry, but somehow not on the GRAS list. 
This is definitely an area where the TTB needs to improve on. 

In other instances I have have had clients rejected in their use of a botanical already approved for other gins! 
The common response seems to be "each case is examined individually" or "we can't speak on other submissions" 
Hopefully you can find a substitute or a workaround for this.

Steve

[FIVE x 5 Consulting]

This used to bug me until I understood TTB/FDA position on this.

A substance can be GRAS as a food item, but not considered safe when added to an alcohol beverage. The clearest example of this is Four Loko, which had added caffeine and which was pulled off the market. Caffeine is obviously GRAS but adding the isolate to an alcohol beverage was deemed to be unsafe.

Another example is Butterfly Pea Flower. It's now on the GRAS list but you can't just add flowers to your spirit formula, because it's a bio accumulator that can have unsafe levels of certain compounds (arsenic or lead if memory serves). So they'll let you use a flavor extract derived from the plant (that's been TTB tested) but they wont let you create the extract yourself in your DSP, because they can't control your sourcing & infusing protocols enough to ensure product safety.

All that said, I too have had TTB reject ingredients that they previously approved and refuse to budge. It can be very frustrating.

If you are originally distilling gin (from a fermented mash), there's a potential "out" for you in the CFR.  Reach out if you want to know more.

 

[Cosmic.Distiller]

On 9/27/2024 at 8:20 AM, Kindred Spirits said:

Sorry to hear that you are running into this issue. 

I have had a number of clients deal with the same problem. Using ingredients commonly used in the food industry, but somehow not on the GRAS list. 
This is definitely an area where the TTB needs to improve on. 

In other instances I have have had clients rejected in their use of a botanical already approved for other gins! 
The common response seems to be "each case is examined individually" or "we can't speak on other submissions" 
Hopefully you can find a substitute or a workaround for this.

Steve

Hi Kindred,

I'm fairly certain you actually can argue for there being a precedent. I recall getting rejected before and we found a previous example that was approved and they were forced to approve us. 

 

Op, that is very frustrating. It is well known borage is a safe edible plant. Honestly, I would just resubmit it in a week or so. It's a stretch if it's not GRAS or theres no precedent, but I definitely got things approved that were previously rejected just by getting a different agent. 

You can also try a cucumber maceration to add as a compound to your batch. Cucurbitacin is juuust under the skin on a cucumber. If you do a light peel, and let it steep in high proof ethanol (not super soluble in water, but is in ethanol) and taste it's progress that might work, but it would probably add a slight color to your gin. You wouldn't want to distill with it in there, cucumber and heat don't go well together. Worth a shot! Just know that cucurbitacins get bitter the stronger their concentration, so could be less is more here.

[Kindred Spirits]

29 minutes ago, Cosmic.Distiller said:

Hi Kindred,

I'm fairly certain you actually can argue for there being a precedent. I recall getting rejected before and we found a previous example that was approved and they were forced to approve us. 

 

Op, that is very frustrating. It is well known borage is a safe edible plant. Honestly, I would just resubmit it in a week or so. It's a stretch if it's not GRAS or theres no precedent, but I definitely got things approved that were previously rejected just by getting a different agent. 

Trust me we have tried that angle, it might work depending on who is reviewing the case, with the person my client ended up with there was no reasoning on the matter with them.
They waited and resubmitted, got someone else who approved it. 

It would be nice to be able to just have things standardized on the TTB side of things.

[Cosmic.Distiller]

1 minute ago, Kindred Spirits said:

Trust me we have tried that angle, it might work depending on who is reviewing the case, with the person my client ended up with there was no reasoning on the matter with them.
They waited and resubmitted, got someone else who approved it. 

It would be nice to be able to just have things standardized on the TTB side of things.

Wow dang! You got a hardass agent! At least resubmitting worked.

[FIVE x 5 Consulting]

I'll just mention that I had a client who resubmitted the same formula over and over (every month for over a year) and eventually Formulation got sick of it and referred them to Investigations. They got a pretty rough audit. You don't want to abuse the Specialists too much.

[Cosmic.Distiller]

2 hours ago, FIVE x 5 Consulting said:

I'll just mention that I had a client who resubmitted the same formula over and over (every month for over a year) and eventually Formulation got sick of it and referred them to Investigations. They got a pretty rough audit. You don't want to abuse the Specialists too much.

Yeah that's excessive 🤣