gin formula regulation

[hawk]

We're working on what our gin will taste like, and it seems we've discovered something odd in the TTB regulations. I've always heard that the botanicals are added during a third pass through the still (i.e., after a stripping run and finishing run to produce the spirit, or using NGS produced elsewhere). What the TTB just told us is that doing this third run makes our gin 'redistilled' and thus we have to go through formula submission. However, if we put the botanicals into the second, finishing run, then we are making 'distilled gin' and do not need to submit a formula. Seems like an odd distinction to draw, but we wouldn't mind saving a step of TTB paperwork.

However, given this, why do we seemingly always hear that botanicals get added on a third run? Does anyone know if doing it in the second run has any down side?

Thanks,

Hawk Pingree

San Juan Island Distillery

[bluestar]

However, given this, why do we seemingly always hear that botanicals get added on a third run? Does anyone know if doing it in the second run has any down side?

Thanks,

Hawk Pingree

San Juan Island Distillery

What you heard from TTB is our understanding as well, except: we assumed we would be making a "distilled" gin, the only variation is that if we start from a GNS, that counts as the single source run, and we don't have to know how it was produced. It only becomes a "re-distilled" gin if we run the three distillations. Since GNS can come from various sources, including continuous operation, but that it is "pure" ethanol, we avoid the formulation issue. Can someone else confirm?

[Denver Distiller]

If you don't mind my advice: just do what they ask. It's much, much faster than arguing, and in the end, it really doesn't matter what the rule is, only what they say the rule is. They mean well, but if you call three different people from the TTB, you're frequently going to get three different answers. It's not really their fault. The rules are very complicated, with many contradictions and doublespeak. They're doing their best to interpret these arcane rules. Unless it's a situation where you they're keeping you from doing something that you know is legal, but they are misinterpreting the rules and keeping you from doing something you wish to do, my unasked for advice is to choose the path of least resistance and do what they ask.

Formula approval seems to take about a month.

Cheers.

[Gwydion Stone]

I completely agree with Todd. It's usually not worth the hassle.

For what it's worth, I've posted the whole chapter on class and type designations here.

[coop]

I completely agree with Todd. It's usually not worth the hassle.

For what it's worth, I've posted the whole chapter on class and type designations here.

We have formulas for just about everything we produce. Easy to get and later on when you submit labels it seams to work better. When they see that a formula has already been approved I think it puts whoever is reviewing documents is in a better state of mind knowing that how we are going to make it has been approved. Coop

[Joe Legate]

What you heard from TTB is our understanding as well, except: we assumed we would be making a "distilled" gin, the only variation is that if we start from a GNS, that counts as the single source run, and we don't have to know how it was produced. It only becomes a "re-distilled" gin if we run the three distillations. Since GNS can come from various sources, including continuous operation, but that it is "pure" ethanol, we avoid the formulation issue. Can someone else confirm?

That's what I was also told and I was not asked to submit a formula.

That said, I would echo Todd and Gwydion's sentiments. Had the TTB requested a formula, we certainly would have complied just because it's easier than fighting a battle that ultimately doesn't matter. Getting the formula approval is too easy especially compared to the mountain of paperwork you have already survived.

[hawk]

Thanks to the group who replied on this. The one thing that's clear here is that the rules confuse everyone.

We called in to the TTB formula and label people. Person I talked with first on the phone said that this is not redistillation and thus doesn't require formula for gin. But I asked another question she couldn't answer, so she referred me to an expert who called me back and was very nice.

At first he was saying that any third-pass gin-making was redistillation, but later he backed away to: a third pass using spirits we made ourselves from scratch was not, but if we did a run 50-50 with our spirits and NGS, that would be redistillation. He encouraged me to summarize what I'd heard from him in an email so he could be sure we had the same understanding. When I did that, his email came back saying that NEITHER of those two situations was redistillation: in either case, that pass with the botanicals is the first pass making gin and thus its 'original distillation.'

All of these positions make sense, depending on assumptions and definitions. But we'll go with his final word since it saves us a formula step.

Hawk

[bluestar]

At first he was saying that any third-pass gin-making was redistillation, but later he backed away to: a third pass using spirits we made ourselves from scratch was not, but if we did a run 50-50 with our spirits and NGS, that would be redistillation. He encouraged me to summarize what I'd heard from him in an email so he could be sure we had the same understanding. When I did that, his email came back saying that NEITHER of those two situations was redistillation: in either case, that pass with the botanicals is the first pass making gin and thus its 'original distillation.'

Hawk

His final reply makes sense. Only if you take the gin product and distill it again is it a redistillation. How many times you distill to get a GNS as a source material should not matter.