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White Dog, White Whiskey, New-Make, Moonshine...What's in a name?


Guest Rarnold3

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All three BT "White Dogs" have the same formula/sop # (SAZ-4), all three have whiskey down at the bottom in the fine print. Unless their Mash #1, Rye Mash, and Wheated Mash are all the exact same mashbill, than I figure "SAZ-4" is some sort of internal number, not a TTB-approved formula. Not trying to pick a fight with BT or anyone else, but I doubt they went through formulation, and as stated in my last post, labeling approved it based purely on it's merits as a LABEL, not that it's a whiskey or not. I'm not trying to stonewall or make myself look like I know anything, I am merely speaking and looking at this on my understanding and/or experience. If someone can tell that someone in formulation (not labeling) told them that a "whiskey" can be unaged and less than 80% corn, or they sent a formula for approval and it was approved, please let me know... please let all of us know so we can put this "dog" to rest.

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I don't think you're arguing, John. That's a good spot.

Raises more questions than it answers, though.

My best guess is whether or not BT and HH can call these products 'whiskey' they would rather not for their own marketing reasons.

The ways of the TTB become more mysterious every day, which is why it's good that they have the COLA process. If your COLA is honest you can take TTB's approval to the bank, even if it's arguably wrong. I know of some cases where TTB has made mistakes, later recognized and admitted them, and ordered corrections, but allowed the producers to use up label stock, etc.

I've never heard of them ordering a recall. I'm not sure if they can, although Federal agencies can always 'request' a 'voluntary' recall (wink, wink).

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Guest Rarnold3

Just a note...

Heaven Hill's Rye New Make has "Rye Whiskey, Straight from the Still" at the bottom in fine print. Their bourbon whiskey New Make has "Whiskey, Straight from the Still" at the bottom in fine print.

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It's all fine and dandy to allow politicians and lawyers write CFR's that we have to adhere to, but what do those of us that are distillers think? Should grain spirits that are distilled below 190 proof and NOT aged in oak be called a "whiskey," or "spirits distilled from X?" I'm interested to know what our consensus ends up being.

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Guest Rarnold3

Whiskey was whiskey long before the advent of barrel aging. I believe if this style is to become an established, recognizable category, it needs to take on the term whiskey. White Dog, New Make, etc could precede the word whiskey just like Bourbon or Scotch does. A situation similar to rum and tequilla and their aged and unaged spirits.

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Note that Heaven Hill and Buffalo Trace are not calling their white dog products 'whiskey.'

I know the label for BT "Mash Bill #1" product has a class of "whiskey". My own Rye Dog has a class of "whiskey" and it so states on the bottle. I even have a formula for mine that specifically states will be stored in stainless steel barrels. Approved as "other whiskey". The SFWSC recently placed Rye Dog in the category of "American Straight Rye Whiskey" for judging. Seems like it should have been in other whiskey, but that's not what they did.

Many/some consumers seem to initially surprised that some whiskey isn't brown. They think it comes from the still that way. Once explained that it comes from the still clear, then becomes brown through contact with oak during aging, they understand the difference.

btw, I think whiskey needs to be distilled below 160 proof, otherwise it's a spirit.

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I know the label for BT "Mash Bill #1" product has a class of "whiskey". My own Rye Dog has a class of "whiskey" and it so states on the bottle. I even have a formula for mine that specifically states will be stored in stainless steel barrels. Approved as "other whiskey". The SFWSC recently placed Rye Dog in the category of "American Straight Rye Whiskey" for judging. Seems like it should have been in other whiskey, but that's not what they did.

Many/some consumers seem to initially surprised that some whiskey isn't brown. They think it comes from the still that way. Once explained that it comes from the still clear, then becomes brown through contact with oak during aging, they understand the difference.

btw, I think whiskey needs to be distilled below 160 proof, otherwise it's a spirit.

I'm merely asking for clarification purposes for the sake of what has and hasn't been approved by the TTB and if it is possible, according to them, to have formulation approve an unaged, less than 80% mash spirit as a "whiskey" of any sort. So you're saying that you sent in a TTB 5100.51 (Formula and Process For Domestic and Imported Alcoholic Beverages) to formulation and they approved it as "other whisky" and allowed you to put "rye whisk(e)y" on the label? And, for the record, my vote is I think it's dumb to allow "corn whiskey" to be labeled as such as an unaged product, but not other mash whiskies. And yes, I realize the historical implications of allowing corn whiskey to be unaged, but it's really confusing to make it so that (in the regs) all whiskey must be aged in oak EXCEPT if it's this one certain, specific kind that is made from a certain grain... idiotic. So all Ford "Mustangs" will be referred to as "mustangs," unless they're blue, than they're called a Ford "Stallion."

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Paul, it seems that you might be confusing the definitions for the class whiskey and the types rye whiskey, bourbon whiskey, corn whiskey, etc. I don't have the forms in front of me, but I think on the formula there's boxes for class and for type. On my Rye Dog formula it stated class: whiskey, type: n/a. Likewise on the COLA. So on the COLA, TTB listed it as "Other whiskey" which I think is their term for a whiskey (class) that doesn't fall into a specific type within that class. Rye Dog is 90% rye grain and 10% rye malt. I specifically did not use the term "rye whiskey" on the label to avoid any disagreement over whether I was trying to claim the product was of a type that it was not.

The "less than 80% mash bill" doesn't have any meaning for whiskey in general as it is a grain-based spirit. The 80% corn in the mash bill is a distinction to separate this type from another type: bourbon. The types are further distinguished in that bourbon must be stored in new charred oak, while corn whiskey may be stored in used oak containers or non-oak containers.

Until March 1, 1938 you could take your white dog rye whiskey and put it in used oak and still call it rye whiskey. The new charred oak as a requirement came about through the efforts of the Kentucky senators at that time. Chuck can tell you the details better than I.

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Delware Phoenix - it seems to make sense what you are saying about "other whiskey" vs a specific type of whiskey and that the barrel requirement is specified in the description for the type of whiskey, such new charred oak for bourbon.

One thing that still has me confused is the age statement. I keep reading in certain parts of the CFR and the BAM that an age statement is needed for all whiskey aged under 4 years, which would include corn whiskey and "other whiskey." So, is an age statement needed on white dog in the "other whiskey" category indicating the whiskey is aged "0 years in oak barrels" or, if put in barrels for a short time, "aged 3 months in used oak barrels?"

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To be honest, I haven't looked as deeply at the age statement requirements. Admittedly, those regs are written in a highly contorted style.

I know that my white dog product does not have an age statement, unless TTB considers the word "unaged" as an age statement. The BT and Death's Door white dogs don't have age statements. Maybe if it's clear, that's an implicit age statement?

Between the CFRs and the BAM the latter is technically the more correct. The BAM doesn't mention (the class) whiskey being stored in oak containers while the CFR does.

If you take your bourbon, rye, etc white dog and put it in used barrels, then instead of calling it rye whiskey, for example, you have to call it whiskey distilled from rye mash, and I think you have to state what percentage was aged in used barrels. Not sure that info has to be on the front label though.

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I am ignorant of anything that may have happened on March 1, 1938 regarding the Standards of Identity.

What seems to be happening with label approvals is that the TTB is allowing producers to use grain names prominently on the label as long as they are not used right before the word 'whiskey' in the name. In other words, a product called 'Chuck's Finest Whiskey; Radical Rye' or 'Rye Riot Whiskey' would be acceptable even if distilled above 160 proof and aged very briefly in used barrels. It is classified on the COLA as just 'whiskey' or 'other whiskey,' but not as 'rye whiskey,' and so would not trigger the <160 proof and new charred barrels requirement. Everybody wins.

I doubt TTB would regard the word 'bourbon' so generously but they're being sensible in terms of letting people prominently feature their source grain or grains. The difference is probably negligible to the consumer. If the words 'rye' and 'whiskey' are both in the name, regardless of the order, the consumer will get 'rye whiskey' from that, not as the TTB understands that term, but as the consumer understands it.

There seems to be no getting around the touch-and-go aging requirement but resting your still output overnight in used barrels hardly seems prohibitive. Use an old barrel instead of a tank to feed your bottling line and the word 'whiskey' is yours.

In the USA anyway.

The message to consumers, then, is that all whiskeys are aged in wood but not all of them pick up color from the wood, typically because they are aged very briefly. Most consumers will be satisfied with that explanation. I don't think you do yourselves any favor by portraying touch-and-go aging as a trick on the government. Just call it a very light aging that doesn't impart any color.

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A couple points Chuck.

There is no requirement for spirits distilled under 160 proof to be stored in new charred oak, unless you plan on calling it rye whiskey, bourbon, etc. Do not confuse the general requirements for all whiskey from the specific requirements for specific types of whiskey.

Use an old barrel instead of a tank to feed your bottling line and the word 'whiskey' is yours.

Not legal to bottle from the barrel. Must be transferred to a bottling tank, even if you're going to produce single barrel, barrel proof bottlings. There's no way to get an accurate weight or proof otherwise.

Again, the old notion that commercial whiskey by definition would be placed in oak (otherwise it was most likely moonshine, the illegal stuff) doesn't seem to be true anymore. You should check with your contacts at BT and HH to see if their white dog/new make whiskey is being placed in an oak container before bottling. And if so, what kind of container. It could be they have an old wooden fermenter they don't use for it's original purpose. But my guess is it comes straight from the white dog holding tanks to the bottling line.

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