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What Is Craft?


cowdery

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When I first posed this question here a couple of years ago, I did it, admittedly, in a confrontational way that wasn't conducive to thoughtful discussion. I hope to avoid that mistake this time, because it's still a topic worthy of discussion. It's a topic that is healthy for this industry to talk about in an in-industry forum like this one.

One way to frame the question would be what makes micro-distillers more 'craft' than macro-distllers? But the more fundamental question underpinning that one is, what is craft?

I was prompted to ponder this again because someone in another thread mentioned using "malted and pre-gelantized rye flakes" to make, presumably, rye malt whiskey. I know of one macro-distillery that has made whiskey using rye malt but they bought malted rye from a maltster and milled it themselves. Obviously, the flakes are a much more processed ingredient so, in that case, who is the craft distiller?

But maybe more-processed/less-processed isn't a crucial distinction. Maybe a proper definition of 'craft' isn't just 'someone who makes everything from scratch.' Maybe that's one way to be 'craft,' as in practicing the craft in an historically authentic way, but perhaps another way is to use the full range of modern tools, methods, and ingredients to make new, unique, and innovative products? Craft should be non-industrial but should it necessarily be un-modern?

That's just one possible dichotomy. There are many others.

What do you think?

(If any moderator is so inclined, please correct my spelling of 'philosophical' in the subhead.)

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In my opinion it's not the actual product that defines the craft distillery, but the size of their operation. The other distinction is that the craft distillery can kind of make what they want and not have a lot of 'corporate' to deal with to get something new moving along.

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Although making from scratch is one possible facet of "craft"—and one which greatly appeals to me personally—my interpretation of the craft ideal as it applies to distilling is more about the constant intimate involvement of the distiller in the process of distilling, as he/she makes decisions on how to proceed.

I admit that I don't have experience of macro processes, but I'd say that in my opinion as automation increases, craftsmanship decreases—at least where judgement calls are concerned.

The obvious example is making cuts. Is there a person with great experience and skill determining where cuts are made, by taste? Or is there a computerized system that makes the cuts or indicates when cuts should be made, based on time/temperature/proof?

Does it take a craftsman to mill sugar cane? No. So why not buy cane juice and devote your energy, time and skill to turning it into good rum? Do I need to completely learn and perform the related craft of malting, or can I buy malt from someone else and get down to the business of coaxing whisky out of the grain. That's what makes a craft distiller.

I feel that the modern expectation that a "craftsman" must perform or oversee literally every aspect of this endeavor is sometimes misguided, and often ego-driven. Sometimes it's based on completely arbitrary, populist criteria, a good example being here in Washington where "craft" distilling is legally determined by nothing more than making under 60,000 gallons per year, using at least 50% in-state raw materials. As soon as someone sets up an industrial operation making GNS from Washington produce, we'll have "distilleries" popping up all over the place offering "craft" vodka.

I think it's perfectly feasible to make craft spirits on a large scale... if one is willing to hire enough craftsmen to keep the process personal. Do I think that Big Liquor will ever do this? No, I really don't.

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Although making from scratch is one possible facet of "craft"—and one which greatly appeals to me personally—my interpretation of the craft ideal as it applies to distilling is more about the constant intimate involvement of the distiller in the process of distilling, as he/she makes decisions on how to proceed.

I admit that I don't have experience of macro processes, but I'd say that in my opinion as automation increases, craftsmanship decreases—at least where judgement calls are concerned.

The obvious example is making cuts. Is there a person with great experience and skill determining where cuts are made, by taste? Or is there a computerized system that makes the cuts or indicates when cuts should be made, based on time/temperature/proof?

Does it take a craftsman to mill sugar cane? No. So why not buy cane juice and devote your energy, time and skill to turning it into good rum? Do I need to completely learn and perform the related craft of malting, or can I buy malt from someone else and get down to the business of coaxing whisky out of the grain. That's what makes a craft distiller.

I feel that the modern expectation that a "craftsman" must perform or oversee literally every aspect of this endeavor is sometimes misguided, and often ego-driven. Sometimes it's based on completely arbitrary, populist criteria, a good example being here in Washington where "craft" distilling is legally determined by nothing more than making under 60,000 gallons per year, using at least 50% in-state raw materials. As soon as someone sets up an industrial operation making GNS from Washington produce, we'll have "distilleries" popping up all over the place offering "craft" vodka.

I think it's perfectly feasible to make craft spirits on a large scale... if one is willing to hire enough craftsmen to keep the process personal. Do I think that Big Liquor will ever do this? No, I really don't.

I agree with the above. Especially, "the modern expectation that a "craftsman" must perform or oversee literally every aspect of this endeavor is sometimes misguided, and often ego-driven. Sometimes it's based on completely arbitrary, populist criteria,[/i]" I'm intrigued by the recent trend of distillers also getting into farming. I can say that my day is plenty full without having to also be/hire/pay for/operate a farm.

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I am a craftsman in a field totally unrelated to distilling, and I would say that one of the things that makes a manufacturer "craft" is that they can make a distinctive product for less. What that means is that they have ability to leave in the good lumps and bumps and take out the bad ones. Think of bread. 30 years ago nobody would eat a lumpy bumpy loaf of bread. Nowadays people don't consider it bread unless it has nuts and grains and twigs sticking out of it. With a macro manufacturer that becomes very expensive to do convincingly, although big business will always find a way of making something look lumpy and bumpy, if that's what the customers come to expect of a high end product.

Craft is also often found dancing an uneasy tango with expertise. Expertise makes a palatable product on any scale, and consistently. Does anybody remember that article on Dogfish Head Brewery in the New Yorker some years ago? The journalist asked some venerable Belgian Trappist monastery brewer (or whoever it was) what he thought the best beer in the world was. His answer; Budweiser, because they nail it every time, despite pumping out a zillion litres a day.

So where does that leave craft? With the lumps and bumps, and they better be the good ones!

-Dan

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I'll throw two bits behind Gwydion & Scott. Intimate involvement (but perhaps not direct operation) throughout manufacturing is (a) key to being a craft _distiller_.

But I'd like to consider something else that I think goes into making a craft _distillery_. And to do that, let me tell you a tale from the craft cider folks. I recently had a wonderful chat with a fellow cidermaker. Perhaps the biggest cidermaker shy of the national brands. He's certainly a skilled practicioner of the science & art of cidermaking. But he gets little respect and a lot of guff from the 'craft' cider crowd. Producers, academics/advocates and geeky consumers alike. And it grates on him. After our talk, I think I have some new insights.

First, _many_ cider crafters are also cider growers. And this fellow is emphatically not. Deliberately and vocally so. Being a farmer, in addition to a manufacturer, adds a perspective that I think this fellow is missing. I don't know that being a grower is important to craft spirits. Maybe only certain specific ones.

Second, this fellow makes a number of non-traditional cider-like substances. I've decided this is fine. What says that a 'craftsman' has to be bound by tradition? Why can't you use your skills and creativity to innovate? A caveat - I, personally, would distinguish between a producer who developed new products by innovating _from_ tradition, and one who invented them from whole cloth, ignorant of tradition. But I tend to find that's my perspective, not a consumer's perspective. (General trend, not absolute!!)

The third insight goes beyond production. A big part of the issues 'craft' cidermakers have with this fellow's brands is the marketing. It stretches identities and history to the limit. Perhaps further. When this is raised, my colleague simply throws up his hands, and says 'marketing's not my department'. He keeps an ear to a very local market for quality and developement purposes, but otherwise he has no control of his own story. A beverage business is more than production. A distiller may 'craft' a beverage in any setting that provides sufficient control of ingredient and process. But a craft _distillery_ has to market and sell those products.

So my thesis is that a critical aspect of being a craft distiller is retaining control of your own story and message. If you are not involved in marketing and sales, then there's a break in the chain, and the honesty in the story behind your brand falls on the floor somewhere. You took the care to put it in the bottle - you need to make sure it gets all the way to the glass.

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I remember when "micro-brewers" started calling themselves "craft-brewers" because they had outgrown the federal definition of micro and found themselves grouped with their declared enemies, the "macro-brewers". I continue to have a good laugh about it.

Distillers are apparently choosing not to even touch the whole "micro" phenomenon, instead choosing the term "craft" to begin with. That way, I guess we'll never have to deal with the identity crisis of outgrowing our own definition of what we are, like the brewers so ignominiously did. I think that is a good call.

For me, what differentiates a craft brewer from a macro brewer is creativity. The macros are pretty much all brewing the same thing: light lagers. It is the fact that a small brewery can and does brew whatever the hell it wants that makes it interesting and exciting. This is an area where I wish distilleries could compete.

Imagine if there was federal legislation requiring all products bearing the label "beer" to be brewed from a mixture of rice, corn, and barley, and have no discernible yeast character (as was traditionally the case in this country). American craft brewers would never have been able to create the huge number of completely new and unique beer styles that they have come up with over the past few decades.

In my opinion, the TTB's refusal to allow any of our products to differ substantially from those contained in their "standards of identity" is a huge hindrance to what I would call craft distilling. At the moment, all "craft" distillers are allowed to do are those things that have already been done. Why can't I put sugar in with my corn and wheat and label it moonshine? Why can't I take a potato mash and distill it at 160 proof and age it for a few years in oak and call it potato whiskey? Maybe if I literally made a federal case about it and spent thousands on lawyers I could get the TTB to bend their ridiculous rules for me like they have for so many others, but who wants to do that?

Don't get me wrong, I think that the whole AOC thing can be great in some cases. Good Bourbon is one of the things that makes me proud to be an American, and I respect the government's defining and protecting that particular national treasure. However, I feel that a little more room for creativity from the TTB would really put the "craft" back into distilling.

Nick

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Guest Rarnold3

Micro or macro? Craft or industrial? This revolution of craft/micro is really more of a return to pre-prohibition times. To say the so-called "macros" are not craft simply because they survived prohibition (or re-opened soon after) isn't justifiable. And the use of "modern technology" shouldn't be criticized. What was "modern technology" in the mid-18th century? The advent of barrel aging.

What is craft? If you ask me, its any distillery that is surviving, innovating while maintaining consistency, and making customers happy.

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I'll quote John Glazer from Compass Box and say that the simple definition of any "craft" is "making something better for the sake of it."

By that definition I'll say that Rarnold3 is a bit too broad, while others are maybe a bit to narrow.

I'll use the example of what I believe inspired Chuck to write this post in the first place: the Buffalo Trace Single Oak project. Taken by itself, it's hard to argue that this is not a "craft" project. In striving to create the best bourbon possible by narrowing down all the possible aging variables (and one recipe variable: rye vs wheat), they are clearly trying to make a better product. But are they doing so "for the sake of it"? Or is there a level of business calculation in the positive PR such an endeavor will produce? My assumption is a bit of both; the distillers themselves are probably excited about making something better for the sake of it, while the business people in the company were convinced to sink the time and money into it for the PR. This, to me, precludes the distillery from being called a "craft distillery."

Another knock against them: in addition to some very fine products, they also make some cheap junk. This is a straight forward business decision that all the big distilleries make; for the sake of market segmentation they make products ranging from cheap to very expensive and everything in between to reach every possible consumer. Nothing wrong with this, but the idea of "making something better for the sake of it" means that every product you make, you strive to make it as good as it can possibly be. The big distilleries don't meet this requirement.

I'll agree with Chuck that "from scratch" need not be a requirement, and that the term itself is incredibly hard to define. The pre-gelatinized flakes that Chuck mentions, for example, are just a small step from raw grain, allowing distillers (or brewers, who use them extensively) to use rye, wheat or corn without having to invest in a cereal cooker. The distance in terms of processing from raw to flaked grain is not much different than from raw to malted grain, and almost no one in the US malts their own barley. Trying to draw a line in the sand that says when a process begins "from scratch" is a silly way to define "craft." I think the motivation behind the products and the quality of the products themselves, ALL the products a given distillery makes, is a better indicator of whether they should be considered "craft."

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Guest Rarnold3

I agree with a lot of what you say, but this line causes problems for me.

"but the idea of "making something better for the sake of it" means that every product you make, you strive to make it as good as it can possibly be."

Many of the craft guys making aged spirits release whiskey that is too young. Don't get me wrong, I'm a huge fan of the "craft" guys doing what they can to release an aged spirit in a time that makes any practical sense financially. But there are times when "craft" guys release an aged spirit knowing that it is "good," but it's not "as good as it can possibly be." The mindset is that once they get going, they can release a more mature version under the same or different name that IS "as good as it can possibly be." I wouldn't call this "market segmentation" exactly, but there are similarities.

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Nick wrote, "Why can't I put sugar in with my corn and wheat and label it moonshine?"

You can. There is no TTB rule to stop you. Use of the term "moonshine" is not regulated.

Nick wrote, "Why can't I take a potato mash and distill it at 160 proof and age it for a few years in oak and call it potato whiskey?"

Because potato is not a grain. It's not just the TTB/USA. You can't call a potato spirit 'whiskey' in most of the world. But you can make it and sell it under some other name, such as 'potato spirit.'

TTB seems widely misunderstood in this regard. Nothing in the Standards of Identity dictates what you can or cannot make, it just restricts what you can call it. What you're really complaining about, then, is that you can't make anything you want and call it anything you want.

There is certainly some room for improvement in the TTB regs. For example, I would argue that the designation 'blended whiskey' should be limited to combinations of whiskeys of different types. Under current rules, a mixture of 20% whiskey and 80% vodka can be labeled 'blended whiskey.' What you (and others) seem to be proposing is an abandonment of standards altogether. That would not be good for anyone.

No one is restricting the creativity of craft distillers. You may make anything you can conceive. The fact that you can't arbitrarily call it 'whiskey' just because you happen to like that word, hardly seems unduly restrictive. If I make a coat out of rabbit fur, can I call it mink?

This notion that the TTB rules are somehow inhibiting the creativity of craft distillers is an absurd misstatement of reality.

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The way "craft" is used in this forum context, to me, implies "hand craft" AND small, and a certain amount of experimentation

A few larger distilleries could call themselves "craft" because they are very meticulous at producing a consistent and desirable product (check some of the dictionary meanings of craft) but as I said, as we use the term it implies hands on and small.

To me it means "hands on" ALL the way. There are obviously degrees of "craft".

At one end of the scale is the maker who sows his own grain and finishes by applying a hand written label.

At the other end is a distiller who purchases mostly processed ingredients and uses a lot of automation and computer monitoring, but does the cuts by smell and taste, and then applies an almost generic label by machine.(assume they both produce a very good product)

If in the second example the distiller did the cuts by hydrometer readings only, I would not classify that as "craft", could be a "micro distillery" but not "craft"

IMHO

PeteB

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But the more fundamental question underpinning that one is, what is craft?

An excellent question and one that goes to the heart of what some? many? are trying to do.

My back of the envelope definition is that "craft" means making something of sufficient uniqueness or complexity that it cannot reasonably be replicated on a large scale by large scale processes. Basically, if what you're doing scales to high volume, then it doesn't fit this definition of "craft". I sure don't accept "small" as being synonymous with "craft" - if I use the same inputs as a big producer, to make a product similar to what the big producer makes, then I'm not any more "craft" than they are, no matter how carefully I make my cuts.

I do realize that, by this definition, a big chunk of micro-distilleries (and micro-brews and micro-etcs) wouldn't qualify.

But to be honest, that's a marketing perspective. In engineering terms, making good product in high volume is every bit as much of a craft as making doubleplusgood product in small volume - it's just a different type of craft.

All IMO, etc.

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Mr. Cowdery asserts that the TTB would approve the labeling of "potato spirit" that was distilled at 160 proof. He is completely incorrect about that, isn't he? I know that the TTB allows "vodka" to be made from pretty much anything, but when it comes to less rectified spirits, there is only a short list of possible ingredients allowed by the TTB.

"Formulations" are a bag of worms that I have not yet had to open in my career, but from my understanding of the law, formulations are more meant for liqueurs and other such blends of spirits and other ingredients, not for simple distillates. A simple mixture of potatoes, yeast, and water, upon distillation, shouldn't fall under the category of a formulation, should it?

Would the TTB allow a spirit produced from distilled honey wine at less than 190 proof? Would that be a "brandy" because it is distilled from "wine" or a "rum" because it is distilled from "sugar"? Or, as Mr. Cowdery would seem to think, is it just a "honey spirit"? I've read nothing in the CFR that indicates that simply tagging "spirit" onto the end of a product's name makes it OK by the Standards of Identity, as convienient as that would be for all of us.

Mr. Cowdery completely missed the point of my post. True, I can distill anything that I would like. True, I can't call my distillates anything I'd like. The point is that there are distillates that I can make which are completely outside of the standards of identity, and therefore I can not call them ANYTHING AT ALL which means that I can't market them. The TTB would not approve the labeling of "moonshine" made from a mixture of corn, wheat, and sugar (and distilled at less than 190 proof) because it does not fit into any approved class of distilled spirit, regardless of what the brand name happened to be. Am I wrong about this?

Nick

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Thanks for the tip, Denver, but I was unable to find any instances of "distilled spirits specialty" in the entire Code of Federal Requlations. A more thorough search of the SOI specifically also returned no hits. Was there a specific section of the CFR that you are refering to?

I was able to find "distilled spirits specialty" in the Beverage Alcohol Manual, however. Perhaps that is what you are talking about?

It would be strange if the TTB included a class of spirit in the BAM that is not in the CFR, so I'm very interested to see what part of the CFR they were thinking of when they included that class in the BAM. The BAM says that distilled spirits specialty "product definition is unique to composition and production of distilled spirits product". I guess that would mean that you could call it pretty much anything you wanted if your lawyer was good enough and the label had "distilled spirits specialty" written somewhere on it.

I think that it is apparant that the TTB needs some means of approving the labeling of any given product, and a distilled spirits specialty class would help them to do that. But if the CFR does not include distilled spirits specialty anywhere in the SOI, I think that is just another example of how the SOI could use some revision.

Either way, it sounds like the TTB is willing to approve pretty much any product as a "distilled spirits specialty", so now I'm even more excited to distill up some unique and un-heard-of spirits! Thanks again, Denver.

Nick

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Search the SOI just for the word "specialty" and you'll find its relevant uses.

Templeton got a "Distilled Spirits Specialty" label approved for a mixture of rye whiskey and cane spirits.

If you tell the TTB what you have made they will tell you what you can and can't call it but they won't tell you, "you can't make that because there's no name for it." That's not how it works. If it's an otherwise legal product, you can make it and sell it. Mostly you can call it whatever you want so long as the name you choose doesn't have a legal meaning you can't satisfy (e.g., whiskey). You need an official category for the small print, but Distilled Spirits Specialty is the catch-all. "Liqueur" is the other nearly universal catchall. And "flavored vodka" covers just about everything based on neutral spirits.

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I believe that I am officially beating a dead horse, and I apologize, but just to clarify...

If by SOI what is meant is 27 CFR 5.22 - The Standards of Identity http://edocket.access.gpo.gov/cfr_2010/aprqtr/pdf/27cfr5.22.pdf i.e. "the law", then there are no instances of the term "distilled spirit specialty" or "specialty" alone. There is one instance of the term "specialties" that you will find under Class 10; imitations, but if you read that class, I'm sure that you'll agree that the specialties that they are talking about are not "distilled spirit specialties" as you seem to be defining them.

On the other hand, if by SOI what is meant is chapter 4 of the BAM (as was referenced above by Denver Distiller and myself) then there is one mention of "distilled spirit specialty" that has already been discussed at length. I'd just like to point out that the BAM is not the law, but a practical guide to the law and the TTB's methods of enforcing it.

Please correct me if I'm wrong, but the TTB fabricated the class "distilled spirit specialty" for the BAM without any basis in law. Not that I blame them or anything, and I think that we all agree they need to be able to approve any given spirit in one way or another. It is amusing though.

The way that I read 27 CFR, it was written with the express purpose of being restrictive and prohibitive of any spirits not explicitly delineated within it. I agree with Mr. Cowdery that restrictive definitions are a good idea in some instances, such as Bourbon. I also agree with his proposed change to the definition of "whiskey" as well.

I'd just like to see a place for spirits distilled in a perfectly normal way, such as a flavorful distillate of potato (I won't call it potato "whiskey" this time) or a flavorful distillate of beet molasses (god forbid I call it beet molasses "rum"). With so many great names of spirits that are possible, it seems a shame to restrict distillers to what has already been done, or something with the boring suffix "-spirit".

It's a slippery slope, I know, but we're going to need to freshen up those archaic laws at some point or another.

Nick

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In administrative law, administrative decisions have exactly the same legal weight as the actual statute. That doesn't necessarily mean the BAM itself is law, but assuming everything in the BAM is based on either the statute itself or an administrative ruling, then you can rely on it. The other good thing about the way TTB works is that they review and approve (or disapprove) everything. If they rule that something is okay then it's okay. They are the arbiters of what the rules mean, we aren't. They'll also work with you to make sure you're using appropriate terminology. Their objective is to make sure the product you make is labeled correctly. Most producers, of course, want to 'help' them make that decision so they find a category they think will work, that is most favorable to their marketing strategy.

Consider too that you rarely see the term "liqueur" in anything other than mouse type. That term is rarely used in a product name.

For example, another term you won't find in the SOI is 'schnapps,' yet there are plenty of products on the market called schnapps. They're all officially classified as liqueurs. Beet Schnapps? Potato Schnapps? Go for it!

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If you tell the TTB what you have made they will tell you what you can and can't call it

Mr. Cowdery has apparantly had much better experiences in his dealings with the TTB than I have. In my experience, the TTB says "we're not here to tell you the class and type of your spirit. Submit your application, and we'll either accept it or reject it." Of course, this was after three weeks of phone calls and multiple emails.

If they rule that something is okay then it's okay.

This is not correct. The TTB can revoke a COLA at any time. Ever heard of Golden Shower Imperial Pilsner?

http://www.2beerguys.com/dogfish/beers/goldenshower.html

The story goes that Dogfish Head Brewing Company was pissed at the TTB (or ATF, I forget when this was) for denying some other label, so they submitted the Golden Shower label to the TTB as a big F-You. As it happend, the TTB approved it no problem, and so Dogfish Head produced it. Hilarious. Of course, the TTB later revoked that label.

I wonder if I could get them to approve Cleveland Steamer Potato Whiskey as a fanciful name for a distilled spirit specialty? Only one way to find out I suppose...

Nick

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Based on the way you've approached this conversation I can see why you've had trouble with TTB. For example, you don't listen very well. "Whiskey" is a regulated term that can't be used unless your product meets the standards for whiskey, which a product not made from grain does not.

And of course the TTB can revoke, but when they do it's because they made a mistake.

I'm not writing this for someone who is just trying to pick a fight, of course, I'm writing it for all of the people reading it who genuinely want to know what TTB does and how it works. How you approach them is important. You will have the best results if you read the rules carefully and do your best to comply. You also need to understand that TTB's job is to make sure labels are truthful and compliant.

The main thing you need to understand is that TTB doesn't care what you make. They just care how you label it.

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Nick, what do _you_think_ makes a spirit whiskey?

Okay, here we go...

For those forum readers who misinterpret my posts easily, let me make it clear that I am responding to a question about my own views on the definition of whiskey, not regurgitating 27 CFR 5.22, which I believe is clear enough on the subject. Most of us seem to agree that that particular definition could be improved upon anyway.

I regret that I don't have an answer to the question, but rather a long list of other questions that I have been asking myself in attempting to formulate an educated opinion on the subject. However, I hope that my musings might come somewhere near satisfying your desire to know my thoughts on the subject.

Should the definition of whiskey be based upon its etymology?

Should the definition of whiskey be based upon its historical production?

Should the definition of whiskey be based upon the common conception of what it is?

Should the definition of whiskey be based upon something rational?

Is whiskey a single unique beverage, or is it a large group of similar beverages?

First, there's the history of the word:

With brevity in mind, I'll speak very generally and say that the first instances of the word whiskey in the English language were based upon the Latin "aqua vitae". It was a clear, un-aged spirit made from the fermentables available to the population producing it, namely grains. Similar beverages such as Eau de Vie popped up in many other countries speaking many other languages based upon the same basic beverage, name, and recipe: "aqua vitae" distilled from available fermentables. In time, it was discovered that aging in wooden casks benefited the quality of the spirit, and such aging became the norm (thankfully, there were no regulatory bodies governing the naming of the spirit back then, and even these rebellious new "barrel agers" were allowed to call their "radically different" new beverage the same name as its predecessor. Is that such a crime? but I digress...)

Second, there's the modern understanding of the word:

In my experience, most Americans think of whiskey variously as a Canadian, Scotch, Irish, or American spirit, or a completely generic spirit (the Asians get no love). The overall expectations are pretty low, other than that it is brown. Even if someone knows that there is a Scotch whiskey that comes from Scotland, an Irish Whiskey from Ireland, etc. they rarely have any idea that the spirit is made from grain. Of those that know that whiskey is made from grain, few if any know which grain or why. I'd say 99% or more of the American population thinks that the defining feature of whiskey is that it is brown.

Third, there's the legal definition of the word:

Cowdery thinks that the definition of whiskey in American law is flawed, and I tend to agree. It's complicated, specific, and vague all at the same time, and could use some revision in my opinion. However, there's no arguing with it; it's the law. But laws can be changed, which means that defining something by the law can be a sticky situation.

Forth, there's the rational understanding of the word:

It would be profoundly rational to define the terms "grain" "water" and "yeast" and say that whiskey is nothing more than a distillate produced from a combination of the three. However, modern production practices utilize enzymes and other useful chemicals not contained in that definition, which might complicate things. Additionally, defining "grain" could be difficult as well. Is grain nothing more than the seed itself? Excluding the husk would make for some complicated processing... Alternatively, including parts of the grass other than the seed would blur the distinction between whiskey and rum, since rum is distilled from the stalk of a grain producing plant, namely sugarcane. Of course, this entire treatment excludes the addition of oak and oak products, which would also be a huge problem. Is oak necessary for a whiskey? If so, what species, type, nominal pore size etc?

Fifth, there's the taxonomy of the word:

It would be nice if whiskey was widely recognized as a general class of spirits full of many different types, but that is not the case. In my experience, whiskey is recognized as a type, not a class. Most people think that Scotch isn't whiskey, Bourbon isn't whiskey, and that Whiskey is its own special brown spirit. However, we all know otherwise, and most of us would like the class of whiskey to be full of a menagerie of types to compare and contrast. But does that mean that no label should bear the term "whiskey" alone since that is nothing more than a class? Should all labels qualify the term whiskey with another term like Irish, Corn, or Potato (had to throw that last one in there to see if y'all're still reading, and it's always fun to throw in a double contraction too).

So where does all of that leave me in my opinion of what "whiskey" is? Very confused.

I'd like the definition to be as simple as possible. I'd like to preserve well-known AOCs (for lack of a better word) like Bourbon and Scotch without cheapening their image. I'd like to allow for the creation of new AOCs and distilling practices that produce a product not unlike what is traditionally recognized as whiskey. I don't currently have a definition that meets all of these requirements, but I do have some examples of specific circumstances and what I think about them.

I'd like to see the bourbon AOC made geographically smaller. Should you really be able to make Bourbon in New Mexico or Hawaii? Doesn't that sort of cheapen the image of Bourbon?

I'd like to see American distillers be able to buy used bourbon, rum, tequila, or sherry barrels, fill them with a double-distilled new make spirit produced from barley malt that is floor malted on site over smoke, age the spirit for 18 years, and call it malt whiskey. No dice. Only spirit aged in NEW oak barrels can be called malt whiskey in this country. I wonder how a 25 year malt whiskey aged in new oak tastes... probably not so good...

I'd like to see creative distillers striving to produce an homage to classic whiskey styles be able to communicate this fact to consumers through use of the term whiskey on their label. If I handed you a drink that tasted like an amazing and complex whiskey and you loved it, would you really think that it would be such a big deal if it happened to be made from 20% potato starch and clearly indicated this fact to the consumer through its name, i.e. "potato whiskey" or "whiskey made with 20% potato mash" etc? Would you be more or less angry over that spirit or one distilled from some grain that is hardly ever used in whiskey production, like sorghum, that called itself whiskey? Ugg. Speaking of sorghum based "whiskies" Have you ever had Maotai? If not, and you're the sort of person that insists that whiskies can be defined as a spirit made from grains, then do yourself a favor and see if you can find a bottle. I wish that I could describe the flavor of it, but it defines its own flavor. I've never tasted anything remotely like it. The pure awfulness of it is painful, but delightfully so. See, I shouldn't even have tried to describe it. Everyone needs to try Maotai. The Maotai burp is truly an unforgettably awful experience, but I love it. Damn I wish I had some Maotai right now.

I could go on and on, but I think that you might get the point.

I appreciate Charles asking me what I think a whiskey is and the opportunity to put some of my thoughts down on paper, but in the end I still don't know. Though it is way off topic (sorry about all of that Cowdery), I'd love to hear other people's opinions on the subject. We all know what the law says, but,

What do YOU think whiskey is?

Nick

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You missed one - what it means by treaty. That's indirect, as treaties don't act directly - but inform new law and modifications to existing law.

Historical meanings are only important for your marketing story. We aren't distilling in the 18th Century - a time when I could call my bottle fermented 'hard' cider "champagne" and no one would have cared or noticed. We need to worry about what a term means to our customers (for marketing), and to our regulators(for labelling). And when push comes to shove, it's the regulators' court and referees. Even if you bring the ball, they get the final say. But the court really is pretty open, with only a few (admittedly Anglo/Franco-centric) hard lines.

This topic is way off subject, but I think that a discussions of how to approach the regulations (and regulators) helps many people.

So here are some thoughts, and I will also try to be brief:-)

* Don't worry about historical, or fanciful, definitions. Look to the regs. Whether you like it or not, they are the final word. Besides, most people don't know what they are drinking. And of the people who do, they often have details wrong. (Tasting room experience speaking here.)

* The regs are complex, yes. Reality is complex - how can the regs be less so?

* The Beverage Manual is easier to sort through than the CFR, yet is supposed to reflect them, in the same way the CFR reflects the USC. Start with the Beverage Manual.

* Read the regs with a combination of curious creativity and utter idiot obtusity. In particular, don't read anything into them. Most of the time I object to unthinking literalism - but in this case, it's required.

* Use words carefully. Some of them have establised meanings. Some don't. Some are geographic based. In your writing, you're confusing material/process based Standards of Identity with geographic AOCs. You may know the difference, and were just writing off the cuff. But you'll cause trouble for yourself doing that.

* There's a spot on the COLA for a 'fanciful name' for a reason.

* You're going to have to spend the time to push paperwork through the system to find the boundaries in the direction you're trying to explore. TTB agents rarely speculate on what they'll decide. Ask a specific question. And the most specific question is a formula and a COLA application. Yes, it takes forever. Better paper than unsalable spirits.

* Tip: if you're doing something creative, get a formula. It will likely come back with guidance as to how to label. If you think that guidance is wrong, or incomplete, work with the formula approver to tweak it. The COLA approver will look at that guidance - but they've been known to be stubborn and literal. It's supposed to be guidance, not definitive. But some COLA approvers will treat it as definitive.

* TTB interpretation isn't uniform. And it's hard to get them to negotiate. I won't say impossible. But it can be very frustrating to see other peoples labels approved when you're banging your head against a wall/agent. Relax. Have a drink.

And what do _I_ think whiskey is? Without cracking open the BAM, I think whiskey is a [edit: non-neutral] spirit distilled from cereal grain products that has been stored in oak containers. And I'm not so sure about the 'cereal' requirement. I don't think that's in the BAM, but it might be in the USC. It sure gets some talk time on this forum - but that's not definitive, and I've been led astray before.

For instance, I know of an approved COLA for a "sorghum whiskey". Now, a second TTB agent's opinion was that the COLA was incorrectly approved - but only because he would have had 'sorghum' separated from 'whiskey' - as in 'Whiskey, distilled from sorghum'. I also happen to know that the formula specifies sorghum syrup as the starting material, not sorghum kernels. (Have you noticed that the monthly production report headings say 'grain or grain-products'?) [That begs the question - could a bourbon be started from a dark corn syrup fermentation? It would make the devotees grind their teeth - but I'm not sure it would be rejected by the TTB.] But the source of all mis-information (wikipedia) lists sorghum as a cereal. And I don't believe the USC mandates the use of the grain kernels. Here's the literalism duncity kicking in. 'Grain' doesn't equal 'kernel'. It also doesn't matter that sorghum syrup is historically used as a molasses substitute. It's not a sugar cane product. It's a cereal grain product. Now _buckwheat_ would run afoul. It's not a cereal, nor even really a grain. You could distill it, but it would be a specialty spirit.

Another agent pointed out that there's no firm defintion of 'stored'. He used '60 seconds, or 60 feet (rolled down the warehouse). Brown/amber is not part of the definition of whiskey. It may be a common expecation. But that's different. Nor is the use of new oak all the time, or for the whole duration. - at least for the most generic of whiskies.

The use of 'whiskey' _is_ both heirarchical, and somewhat modular at the same time. There is the broad class 'whiskey' and then types like 'rye', 'barley', 'wheat'. There are terms that can be tacked in front of, or behind 'whiskey', like 'straight' (more rigid requirements) and 'distilled from grain x' (less rigid requirements). Then there is a second whole structure for 'blended whiskey' - and the blend can be with anything - including potatoe spirits - as long as you say so. _SOME_ of those combinations have specific barreling and aging requirements. But you don't _have_ to fall into the most restrictive category. You_can_ have a generic class 'whiskey', without a narrower 'type'. And often, it's just a matter of what you write in the formula description, and how you emphasize and join words on the label.

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