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Washington NGS?


hawk

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If you mean bulk GNS such as Pharmco-Aaper sells, to my knowledge there aren't any. I registered my opinion on this on my blog:

... as soon as there is an ethanol manufacturing plant—anywhere, even in California—making Grain Neutral Spirits (GNS) from Washington produce, it will be possible for an entrepreneur to purchase that GNS, rebottle it at 80 proof, and qualify as a Washington “craft” distillery, selling “craft” vodka that actually cost less to make than the bottle holding it.
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Hopefully my response here won't anger anyone, but this is an interesting and complex issue here in Washington State, and elsewhere. As a distiller in Washington State I am familiar with these laws, what they allow and maybe more interestingly, how MOST consumers perceive what we put on our labels.

Just to be clear, from reading both the blog referenced and the topic in general, the 51% local Washington ingredients provision is applied PER PRODUCT, not when viewed against the entire production of the distillery as a whole. So a craft distillery in Washington State will not be making any rum unless at least 51% of the base ag produce is grown in Washington State. Maybe this will change as the legislature becomes more familiar with local distilleries and their needs. We'll see.

Regarding the topic in general, the "craft" designation as defined by the state of Washington seems to be the product of the legislature's lack of understanding the DSP processes and where the lines should be drawn, and some "distiller's" desires to produce products that will be sold under less that 100% transparent conditions. This is my opinion only, but a craft distillery might be more accurately described as one that "distills from raw agricultural produce the products that are sold under its brand or identity". Buying NGS from ANY source would seem to be a factor for disqualification in using the craft designation.

If our small industry is to survive in the long term we need to adopt a policy of honesty and transparency that allows the buying public and our trade partners to know exactly what they are getting from us and what we did to produce it. When a producer makes the statement on their label "distilled from 100% Neutral Grain Spirits" and they have the word "distillery" in their name the inference is that we they were the ones doing the distilling. I have been to many small distilleries, seen the bulk totes out in the back and never heard the proprietors mention once that the base for all of their products has been manufactured by ADM of a similar company. It is base deception.

This is not to say that the products that are produced by companies that use bulk NGS as a base are lacking quality or viability. They certainly are not, and there are many absolutely delicious and finely crafted products that have their start as bulk NGS. There needs to be some rules on the language allowed on the packaging of these products, and a dedication on the part of producers to be honest about what they are doing. Allowing bulk based products to live under the "craft" banner, or falsely allowing that halo to shine on them, runs the risk of consumers perceiving all craft products as being somewhat faked and less than genuine.

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As further context, my reason for asking has to do with making gin. We planned to make some gin starting with our own apple cider. That fits within the TTB gin definition, but cider will be an expensive source with its own taste characteristics to balance against juniper and the other botanicals. And we're having some technical problems carrying too much oil through, so that diluting with an ice cube makes things cloudy. With our test still that's even happening on the eau de vie without any botanicals! So both as a potential solution to the oil problem, and with the idea of having a less-expensive version of our gin, we were hoping to locate in-state NGS. As KBFreeRange points out, using non-Washington NGS needs calculating against the 51% rule for craft distilleries.

Interesting argument about the legislature and definitions. My understanding is that the 51% rule was key to identifying craft distilling as an agricultural activity and thus mobilizing that support base. I think I'd agree on the 'relabeled vodka' point, but think there can be lots of craft going into a gin run because of the botanicals and all of the control issues, even if some of the alcohol source was made elsewhere.

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I would argue that making gin from GNS is itself a craft activity, and that is true even if the GNS is not from a craft source. I find it arguable that making a distilled or compounded beverage that must include a GNS, which likely lacks any significant (admittedly, not in all cases) contribution to the special craft nature of the final product, could be considered craft because of the special skill required in the redistillation, compounding, or other flavoring steps typical or historical for the product. Gin is the most obvious example. Now, while that might make gin using GNS from any source reasonably considered craft, that would not make it a product of local agriculture, unless indeed the GNS itself was the product of local agriculture. JMO

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I think Pharmco Aaper has a plant in Washington, but I don't know where the raw materials come from.

The warehouse, not a plant, is in Vancouver WA, and the grains are sourced from wherever they can get them cheapest.

... Just to be clear, from reading both the blog referenced and the topic in general, the 51% local Washington ingredients provision is applied PER PRODUCT, not when viewed against the entire production of the distillery as a whole.

It's my understanding that WSLCB is interpreting the statute in terms of total production.

This is my opinion only, but a craft distillery might be more accurately described as one that "distills from raw agricultural produce the products that are sold under its brand or identity". Buying NGS from ANY source would seem to be a factor for disqualification in using the craft designation. [...] If our small industry is to survive in the long term we need to adopt a policy of honesty and transparency that allows the buying public and our trade partners to know exactly what they are getting from us and what we did to produce it. When a producer makes the statement on their label "distilled from 100% Neutral Grain Spirits" and they have the word "distillery" in their name the inference is that we they were the ones doing the distilling. I have been to many small distilleries, seen the bulk totes out in the back and never heard the proprietors mention once that the base for all of their products has been manufactured by ADM of a similar company. It is base deception.[...] Allowing bulk based products to live under the "craft" banner, or falsely allowing that halo to shine on them, runs the risk of consumers perceiving all craft products as being somewhat faked and less than genuine.

I respectfully object to this characterization; it shows an incomplete understanding of the wide spectrum of craft distilling activity.

It seems to me that the argument against using the term "craft" or "distillery" in connection with products made from GNS generally comes from those who think primarily in terms of whisky and vodka production. With these, the particular craft involved is that of creating a beverage from fermented grains, with specifically-sought flavor characteristics, often aging them on wood.

When making gin, absinthe, aquavit, and most liqueurs, however, the craft involves the use of a more or less neutral base spirit as a starting place. The spirit does not require the fine nuances of flavor and aroma desired in whisky. Throughout the last several centuries, the vast majority of these makers—large and small—have sourced their base spirit elsewhere. This craft involves the blending of botanicals to achieve the specifically-sought flavor characteristics and re-distilling these, using a different form of the distiller's art. Re-distilling is still distilling.

For the record, I'm firmly against the practice of simply re-bottling GNS for vodka and calling oneself a distiller.

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