Paul Tomaszewski Posted June 22, 2011 Share Posted June 22, 2011 Well Ladies & Gents, do I have one for you that is in the league of a few of our last posts. We're submitting new versions of our "white dog" and "black dog" labels only to find that the TTB is deliberating on if "white" and "whiskey" can be on the front label. Furthermore, they are applying this rule to our "black dog" as well. Now, I will say that the TTB specialists that I have spoken with regards to this matter have been more than understanding and reasonable as far as trying to make sense of this situation. However comma the gist is that they are about to require every single dsp that has a product that has "white" and "whiskey" on the front label to amend that given cola to not have those two words on that front (brand) label. Here is my inquiry/response and I am waiting on a reply, they said I should get a call and/or response within the next few days and I'll post that when it comes: Dear Mrs. X, I will attempt to make this information and explanation with regards to our product ID information as to the point as possible. From our conversation today, it is my understanding that formulation and labeling is going to require that any "whiskey-type product" not include the term "white" on the front label in conjunction with the word "whisk(e)y." If that is the case, than I believe it may be worth considering that the regulations be amended and/or notification be sent out to all licensed dsp's of this information explaining the rationale of this measure. I will say that all unaged whiskies that we produce are a "corn whisk(e)y" and can be unaged, whereas some other products that I have seen on the market are not made from at least 80% corn mash, and are unaged "white dogs," but are still labeled as a "whiskey" somewhere on the front label. As per the regulations, if a producer were to make a distilled spirit product of a mash of grain, but not of at least 80% corn, and it be unaged (and distilled at below 160 proof), than that product would be "spirits distilled from grain." I submit that these products are far more confusing and contradictory of the regulations than the term "white dog." Within the distilling community, it is understood that a "white dog" is the unaged, clear grain spirit (that can be a whiskey if that product is at least 80% corn in the mash), prior to it going into a barrel for aging. Is there a possibility that that term could be added to the regulations and, therefore, allow producers to use this term on their front label in conjunction with the term "whiskey" or "spirits distilled from grain" (depending on if their product were at least 80% corn mash)? If there is a case where we can use the term "white dog" in conjunction with "whiskey" on the front label, we would like to use that term on TTB ID 11108001000472. Furthermore, we do use white corn in our production of our unaged, corn whiskies, and, therefore, if we were to use the term "white corn whiskey" on a label, that could also be in reference to our specific use of white vs. yellow corn. With regards to our "Black Dog Whiskey" label (TTB ID 11108001000476). This product is another unaged, corn whiskey product that is produced from a mash of at least 80% corn, however the corn has been smoked, adding additional flavor that carries over to the unaged, clear spirit. The "Black" in the fanciful name is merely a spin on the classic "white dog" term, especially because we do have a standard "white dog" product that we make using a mash of at least 80% corn, but still 100% grain. Finally, we have an additional product that we have produced and wish to continue to label as "Black Patch Whiskey." This product is a corn whiskey made from a mash of our "smoked/dark fired" corn, then aged in used, charred oak barrels and is meant to embody our local area and the production of "dark fired" tobacco. In the case of the term "Black Patch," this is a reference to the area of Kentucky that we are located. The term "Black Patch" refers to counties in southwestern Kentucky (including Christian County) where "dark fired" tobacco is produced and where there was a civil uprising in the early 1900s that is of much historical significance for this area, known as the "Black Patch Wars." The "Black" on the label for this product is not so much in reference to any color of the product, but of this location reference. Furthermore, if "white" or "black" is not allowed on a front label, than what of other colors, particularly if it is part of a location (ie "Blue Ridge" or "Red River" or "Green Mountains"). I understand and appreciate that your primary role in regulating the use of these colors on labels is to ensure that these products are truthful and not confusing to the consumer. However, I do ask that you and all TTB authorities take into account that there are various historical and location references to these terminologies and that the issue here is if a product is legally whiskey or if it is merely a "spirit distilled from grain" vs. if white is on the label or not. Link to comment Share on other sites More sharing options...
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