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"White Whiskey" part 2


Paul Tomaszewski

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Due to this being a follow-up to a past post, I wanted to provide this in a new post so all interested parties may see how/if this will affect them. So I believe I have a final word from the TTB on the "White Whiskey" labeling issue. Basically, here goes, if you use the word "white" or "white dog" or anything that has "white," in conjunction with "whisk(e)y," you can put it on the front label. However, "white dog" (or white or white whatever) may not appear in close proximity with the class and type disignation "whiskey." Furthermore, and I quote, "the product is not allowed to be classified as a 'whiskey' if the product is unaged UNLESS it is a corn whisky" (I hope by now we all know what a corn whisky is). If the product fits the standard of identity for "corn whisky," than it must be so designated on the label, which I understand as meaning that if you are talking about an UNAGED, CORN whiskey, you MUST label it with the designator of "corn," as opposed to simply "whiskey." This came directly from the director of formulation for ALFD. So, if you don't like it, disagree, or believe it to be untrue, there ya go. Does this mean that all "white whiskey" products are going to be forced to change their labels? Maybe eventually, maybe never, but I would mentally prepare myself that any unaged, whiskies that are not "corn whiskey" products may come to be forced to be labeled as "spirits distilled from grain," or something close to that. Finally, if you have "white" on the front label in "close proximity" to the word "whiskey," you may have to change that as well.

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"Whisky" is an alcoholic distillate from a fermented mash of grain […] stored in oak containers (except that corn whisky need not be so stored) [...] and also includes mixtures of such distillates for which no specific standards of identity are prescribed.[...] [Whiskies] which have been stored in the type of oak containers prescribed, for a period of 2 years or more shall be further designated as "straight".

[...]"Whisky distilled from bourbon (rye, wheat, malt, or rye malt) mash" is whisky produced in the United States at not exceeding 160° proof from a fermented mash of not less than 51 percent corn, rye, wheat, malted barley, or malted rye grain, respectively, and stored in used oak containers; and also includes mixtures of such whiskies of the same type. Whisky conforming to the standard of identity for corn whisky must be designated corn whisky.

There is no specification for time in storage for non-straight whiskies; you could put it in a barrel for an afternoon. They don't even have to be "charred new oak containers" if you're not producing a specified type of whisky. I see no reason why a properly formatted label for a white whisky with the description "Whisky distilled from (your grain here) mash" would not be in compliance.

I believe what the TTB is trying to do is to protect the identity of the class from a radical innovation that opens too much room for abuse. I actually tend to agree. These "White ____" designations were essentially developed as a way to sell unaged liquor and generate cash flow while the proper whisky is aging.

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Due to this being a follow-up to a past post, I wanted to provide this in a new post so all interested parties may see how/if this will affect them. So I believe I have a final word from the TTB on the "White Whiskey" labeling issue. Basically, here goes, if you use the word "white" or "white dog" or anything that has "white," in conjunction with "whisk(e)y," you can put it on the front label. However, "white dog" (or white or white whatever) may not appear in close proximity with the class and type disignation "whiskey." Furthermore, and I quote, "the product is not allowed to be classified as a 'whiskey' if the product is unaged UNLESS it is a corn whisky" (I hope by now we all know what a corn whisky is). If the product fits the standard of identity for "corn whisky," than it must be so designated on the label, which I understand as meaning that if you are talking about an UNAGED, CORN whiskey, you MUST label it with the designator of "corn," as opposed to simply "whiskey." This came directly from the director of formulation for ALFD. So, if you don't like it, disagree, or believe it to be untrue, there ya go. Does this mean that all "white whiskey" products are going to be forced to change their labels? Maybe eventually, maybe never, but I would mentally prepare myself that any unaged, whiskies that are not "corn whiskey" products may come to be forced to be labeled as "spirits distilled from grain," or something close to that. Finally, if you have "white" on the front label in "close proximity" to the word "whiskey," you may have to change that as well.

it has to age for 72 hours in wood to be able to call it white whiskey. charred or uncharred.

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One could also argue that "you can age a whiskey in a very, very, very used barrel for a longer period of time (say months or even years) and not get a whole lot of color and/or flavor, perhaps so little that the whiskey still looks white." Certain Scotches out there (ie Ardbeg) tend to have a very faint color even after being aged for 10 years due to their aging process/techniques. In the end, it's what formulation says because that's who's in charge. Investigators/agents can advise them, but they still answer/refer to what ALFD determines is going to be accepted for given practices. Again, the true issue here seems to be WHAT are you bottling? Are you making an UNAGED CORN WHISKEY or an UNAGED SPIRIT DISTILLED FROM GRAIN that you would like to call a whiskey but can't because it has yet to go into oak for ANY period of time? Aging time may end up being another sticking point if all of us start aging in wood for so many seconds, minutes, or hours in order to just be able to call our "spirit" a "whiskey," hopefully I won't have to go this route again and it take another 4 months to get a final word on the situation. Case in point, when giving tours at our facility we use a bottle of "20 hour old bourbon" that has a very light, peach-like color that you can see it picked up from it's short rest in a new, charred oak barrel. However, I've also aged some whiskey for over six months in a used, charred oak barrel that had been previously used four times and the color is almost indistinguishable.

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There is no specification for time in storage for non-straight whiskies; you could put it in a barrel for an afternoon. They don't even have to be "charred new oak containers" if you're not producing a specified type of whisky. I see no reason why a properly formatted label for a white whisky with the description "Whisky distilled from (your grain here) mash" would not be in compliance.

I believe what the TTB is trying to do is to protect the identity of the class from a radical innovation that opens too much room for abuse. I actually tend to agree. These "White ____" designations were essentially developed as a way to sell unaged liquor and generate cash flow while the proper whisky is aging.

That's what I've understood also from TTB reps.

And Paul's statement...

> However, "white dog" (or white or white whatever) may not appear in close proximity with the class and type disignation "whiskey." Furthermore, and I quote, "the product is not allowed to be classified as a 'whiskey' if the product is unaged UNLESS it is a corn whisky"

As Paul's is a direct quote from TTB regarding UNAGED whiskey, so it doesn't apply to the 'in the top-out the bottom' aging method. There's no standard for minimum 'aging' by the TTB for the broad term whiskey. Folks on this forum have beat that one to pieces.

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Where I disagree with Paul is that nothing has changed or is changing.

The TTB representative Paul talked to described what the rules are and have always been. The people I know who are selling 'white whiskey' have all, in fact, exposed their spirit to wood in order to achieve the 'whiskey' designation. If for some bizarre reason it's important for a producer to avoid any contact with wood, then a product so made may not be called 'whiskey,' but if the spirit meets the "stored in the type of oak containers prescribed" requirement, then it can be called 'whiskey.'

Put another way, if you have an approved label for a 'white whiskey' product, there is no reason to believe you are going to be forced to change that label, as nothing about the rules or how they are interpreted has changed.

Another issue, discussed elsewhere, is that American rules in this regard are at odds with EU and other international rules, which require a three-year minimum aging period.

There is no '72 hour' rule. That is simply false.

The old joke in Kentucky is that if you pour the distillate into an oak bucket and carry it across the room, it will be whiskey by the time you get there.

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Cowdery, the way the standard is written for Corn Whiskey does not require contact with wood. It only states that if it is aged, it must be in new UN-charred barrels. That's the way I read it.

Where I disagree with Paul is that nothing has changed or is changing.

The TTB representative Paul talked to described what the rules are and have always been. The people I know who are selling 'white whiskey' have all, in fact, exposed their spirit to wood in order to achieve the 'whiskey' designation. If for some bizarre reason it's important for a producer to avoid any contact with wood, then a product so made may not be called 'whiskey,' but if the spirit meets the "stored in the type of oak containers prescribed" requirement, then it can be called 'whiskey.'

Put another way, if you have an approved label for a 'white whiskey' product, there is no reason to believe you are going to be forced to change that label, as nothing about the rules or how they are interpreted has changed.

Another issue, discussed elsewhere, is that American rules in this regard are at odds with EU and other international rules, which require a three-year minimum aging period.

There is no '72 hour' rule. That is simply false.

The old joke in Kentucky is that if you pour the distillate into an oak bucket and carry it across the room, it will be whiskey by the time you get there.

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Cowdery, the way the standard is written for Corn Whiskey does not require contact with wood. It only states that if it is aged, it must be in new UN-charred barrels. That's the way I read it.

Absolutely correct. I didn't mention it because the corn whiskey exception is well established, Paul explained it correctly in his post, and it's peripheral to this discussion. We're not talking about corn whiskey. That's something everyone on this forum should already know.

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Funny how everyone is a legal expert on this topic. I interpret the standard, which also includes the content "and also includes mixtures of such distillates for which no such specific standards of identity are prescribed" to mean that if you are not corn whisky, Bourbon, Light whisky, ...... that you are just classified as WHISKY. If you are distilled at below 190 proof, not aged in a barrel, new or used, bottled above 80 proof and kinda smell and taste like whisky, I think this clearly (no pun intended) makes you whisky.

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I only brought up Corn Whiskey because it is the exception, to aging. But there's also that its an exception in a different way. You aren't required to call it Corn whiskey if its over 80% corn in the bill. Only that if you want to call it corn whiskey, it has to be 80% corn. You could make whiskey with 80% corn and call it white whiskey which is what I thought this was all about. The use of the term white whiskey. I meant no disrespect Cowdery.

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Where I disagree with Paul is that nothing has changed or is changing.

The TTB representative Paul talked to described what the rules are and have always been. The people I know who are selling 'white whiskey' have all, in fact, exposed their spirit to wood in order to achieve the 'whiskey' designation. If for some bizarre reason it's important for a producer to avoid any contact with wood, then a product so made may not be called 'whiskey,' but if the spirit meets the "stored in the type of oak containers prescribed" requirement, then it can be called 'whiskey.'

Put another way, if you have an approved label for a 'white whiskey' product, there is no reason to believe you are going to be forced to change that label, as nothing about the rules or how they are interpreted has changed.

Another issue, discussed elsewhere, is that American rules in this regard are at odds with EU and other international rules, which require a three-year minimum aging period.

There is no '72 hour' rule. That is simply false.

The old joke in Kentucky is that if you pour the distillate into an oak bucket and carry it across the room, it will be whiskey by the time you get there.

Actually Chuck, you are wrong. Simply because there are distillers out there bottling completely unaged product that is neither "whiskey" or "corn whiskey." I'm not about to start calling out any other adi members or craft distillers, so let's use the big boys for an example.

Case in point, Buffalo Trace White Dog Mash #1 (TTB ID 10264001000042), as I understand, is unaged. However, the label does state "WHISKEY" on the front label as its legal class description. Now, one could argue that this specific product is produced at "at least 80% corn mash," and, therefore, can be called "whiskey." But, based off of the explanation given by formulation at the top of this thread, that would mean that the product would have to be called "corn whiskey." Looking at another example, let's use Buffalo Trace White Dog Rye Mash (TTB ID 10264001000040). I believe this one is even easier to explain as it clearly states on the label that it is distilled primarily from rye. Therefore, unless this spirit also touches oak at some point prior to bottling, it too is not a "whiskey." Both back labels also give explanations as to these being unaged products that are "raw, clear, un-aged and high-proof distillate right off the still."

Looking at another large producer, let's take Heaven Hill's Rye New Make (TTB ID 10362001000171). In fact, this one is almost funny based on the fact that the front label reads, "RYE WHISKEY STRAIGHT FROM THE STILL." Again, understanding what formulation has ruled on what is and is not whiskey, the only way you can produce a "RYE WHISKEY" is if your "RYE SPIRIT" is aged in new, charred oak. Now unless anyone knows that, without a doubt, both BT and HH are running their White Dogs/New Makes through oak at some point in time (and for HH Rye New Make, new, charred oak), they should be labeled as "spirits distilled from grain" as Maker's Mark's White Dog is clearly labeled (TTB ID 11004001000096). Now if both BT and HH are running their spirits through wood in order to achieve the designation of "WHISKEY," than putting a statement such as "Straight off the still" seems a bit misleading to me, but that's just me.

Again, I've seen, tasted and know of various of "us" that produce UNAGED spirit that's never touched wood and still label it as "whiskey" and/or have "White in close proximity" with the word "whiskey." The Public COLA registry is out there for all to view, and based on my initial posting for this thread, many, many labels out there are not in compliance with the standard of identity for "WHISKEY." You are right in that the regs have never changed. However, I believe that there are folks out there selling unaged spirit that shouldn't be labeled as "whiskey" doing so and they do have approved labels. Based on my conversations with ALFD, everyone who fits that category is going to be contacted by TTB and those labels will be forced to be amended and/or surrendered.

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Paul,

You are correct only insofar as if there was no contact with oak whatsoever, then it can't be called 'whiskey,' but if one has met the requirement of minimal wood contact, then it's whiskey, and there is no requirement that you put "aged 5 minutes" on the label.

Is it fair to call something that spent five minutes in wood "unaged"? Of course it is.

I would think that if someone has slipped by with a 'whiskey' that truly has had no contact with wood, then rather than change the label, they could simply and cheaply add brief wood contact to their process. I am confident that the people selling 'white' products -- especially the major producers -- are familiar with the rules and have followed them.

For Heaven Hill to label its product "rye whiskey," the minimal wood contact would have to be with a new, charred oak barrel, which obviously raises the cost, but not prohibitively for a small release. That is exactly what they did to qualify the white whiskey made at Mt. Vernon as "rye whiskey." The 'cost' is not the full cost of a new barrel, it's the difference between the cost of a new barrel and the re-sale value of a used one. When you can certify that the 'used' barrel was only 'used' for five minutes, that difference might be pretty small.

My bigger point is that nothing has changed. That has always been the rule. Maybe there have been some lapses in interpretation or enforcement, but the rules haven't changed.

This tendency of some people to over-complicate and misconstrue the rules must make it tough to be a TTB agent.

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"This tendency of some people to over-complicate and misconstrue the rules must make it tough to be a TTB agent."

Actually, I think it's ironic that the folks who are over-complicating and misconstruing the rules aren't the ones producing the product. We quite frequently get labels rejected with an explanation why we can't do "xyz" yet there are hundreds of labels out there that say exactly what we'd like to. And yes, we do follow the rules, read the rules, & understand the rules.

Paul is simply posting what we've been told directly from the source. No hearsay, "we think", or supposition about it. Since he was trying to give others out there that might be in our situation a head's up so they have time to prepare, it was simply a courtesy to our fellow producers.

Have a happy day, folks.

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"This tendency of some people to over-complicate and misconstrue the rules must make it tough to be a TTB agent."

Actually, I think it's ironic that the folks who are over-complicating and misconstruing the rules aren't the ones producing the product. We quite frequently get labels rejected with an explanation why we can't do "xyz" yet there are hundreds of labels out there that say exactly what we'd like to. And yes, we do follow the rules, read the rules, & understand the rules.

Paul is simply posting what we've been told directly from the source. No hearsay, "we think", or supposition about it. Since he was trying to give others out there that might be in our situation a head's up so they have time to prepare, it was simply a courtesy to our fellow producers.

Have a happy day, folks.

That's what's known in the business as a cheap shot, especially aimed at someone with my credentials. I don't have a quarrel with Paul's reporting, my disagreement is with his interpretation and his mistaken conclusion that the sky is falling. I have no doubt it can be frustrating as a new producer trying to figure out exactly what the industry regulators require, especially when you're trying to innovate, and I know of TTB rulings that might be called non-conforming, but none of that means a major change in the rules or their enforcement is in the offing, a conclusion Paul's own reporting does not support. It doesn't do you any good, as a small businessperson, to waste time worrying about a non-problem. That's my 'head's up' to the members.

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I could care less if I “put in the last word” or “have to respond in order to assure myself and make others believe that I’m right,” but this is highly uncalled for. First of all, I’ve never said the sky is falling Chuck. In fact, in my initial post, I did explain that maybe the TTB will get around to addressing this said issue with all folks involved OR maybe they won’t. However, I do know that folks in the industry appreciate me informing them of this latest experience, particularly some of those at the top of this organization. I’m sorry if we’ve offended you, considering “your credentials” and all. I’m sorry, I tend to think that those of us that start our own federal and state-regulated distilleries from scratch without big corporate funds, and are helping to push the envelope in an industry that is dominated by a few mega-conglomerate international corporations that are churning out a mere few examples of what is possible to make out there. I WISH the American whiskey market was anything close to that of the level of development that the (for example) Scotch Whiskey market is currently at, and when that day comes it will be because of not the big guys who make bourbon, bourbon, bourbon, and maybe rye (because, let’s face it, they enjoy the “status quo” because they’re on top), it will be because of us folks that are pushing the boundaries of this industry. I won’t go into my past prior to distilling, I’m sure many folks out there wouldn’t be all too impressed, but it says a lot for the comments that you’ve made in such an arrogant manner and I’m sure many folks in my place feel the same as I do reading your ever-so-bold postings and your assumptions that you are making about all of these unaged products being aged in some way or not and how you cannot accept the facts that I have lined up for you. How about overcomplicating things by assuming that it’s okay to “age a spirit/whiskey in oak for a period of time” but still call it unaged? I can tell you what the folks in formulation have told me. They have said that if is unaged (ie, has never ever ever EVER touched oak in any way, shape or form), then it’s unaged and isn’t whiskey UNLESS IT IS CORN WHISKEY. However, they have told me that if you age it for ANY period of time, it is then considered “aged” and, therefore, it would be misleading under their standards to call it unaged. How many times have you talked to formulation? Can you tell me who the director is? Why don’t you call them up and give them the argument you are giving us in defense of the many labels, to include the big producers, and how/why they are or are not whiskey? Now, if you happen to know that BT and HH are, without a shadow of a doubt, passing their “unaged spirits” through wood, than my hat is off to you my good man. But, I am merely making assumptions, from their very own products that they CLEARLY put on their labels for all to see, I’m sure many that have looked at those labels and will in the future can understand how I have gotten to my current conclusions on those products. Furthermore, I can look up various other labels that are not in compliance with the standards, that I agree never have changed, but have not been applied correctly over the past years as this industry goes through some much needed growing pains. Case in point, I have a label right now that is approved as a “straight bourbon whiskey” and never says anything about being “straight” or “bourbon,” so I have to inquire as to how/why that designation was given and how we can amend it. As the good lady in NY said, “I’m done.”

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I'm not attacking you, dude, just disagreeing with you, so the angry rant and ad hominum attack is really uncalled for. I'm also a little confused because you're posting here under multiple identities. Please have a nice day. Sorry you feel the old man on the internet was mean to you.

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That's what's known in the business as a cheap shot, especially aimed at someone with my credentials.

Cowdery, you've got me curious. I see you have a blog and you've published your own book, but what qualifies you to lecture distillers on COLAs? By and large your posts contain tolerably accurate information, but I don't seem to be the only distiller who has found them to be quite unhelpful all the same. It seems to me that you talk like someone who has never applied for a COLA, but I could be mistaken. Apparently you're a lawyer as well. Perhaps you have dealt with COLAs in that line of work?

I mean no offense, I'm just honestly curious. How much practical experience do you actually have obtaining COLAs other than talking about it on this forum?

Nick

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The cheap shot was "the ones producing the product" part, as if running a still has anything to do with interpreting rules. In addition to being a lawyer, I have worked in and around the distilled spirits industry for more than 30 years, working with virtually every major producer, so I just might know a few things.

But even more to the point, why can't we argue the merits rather than immediately attacking the person? Tell me why I'm wrong, don't tell me why I have no right to speak. I offered the opinion that Paul is exaggerating and misinterpreting, but I never questioned his right to have and express his opinion.

At this point in my distilled spirits career I'm primarily a journalist. Telling journalists to shut up and go away tends to be a bad way to promote a product you want the public to trust and buy. Questions and scrutiny are something some in this young business seem to have a problem with, and that will be your loss, not the public's.

But if you find my views and analysis intolerable, use the forum's 'ignore' feature and you'll never be bothered by me again. That's why it's there.

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The cheap shot was "the ones producing the product" part, as if running a still has anything to do with interpreting rules. In addition to being a lawyer, I have worked in and around the distilled spirits industry for more than 30 years, working with virtually every major producer, so I just might know a few things.

But even more to the point, why can't we argue the merits rather than immediately attacking the person? Tell me why I'm wrong, don't tell me why I have no right to speak. I offered the opinion that Paul is exaggerating and misinterpreting, but I never questioned his right to have and express his opinion.

At this point in my distilled spirits career I'm primarily a journalist. Telling journalists to shut up and go away tends to be a bad way to promote a product you want the public to trust and buy. Questions and scrutiny are something some in this young business seem to have a problem with, and that will be your loss, not the public's.

But if you find my views and analysis intolerable, use the forum's 'ignore' feature and you'll never be bothered by me again. That's why it's there.

Since this was directed to my post, I do feel obligated to respond. Ironically, yet again, is the fact that you chose to take my post personally. When, in fact, I wasn't directly referencing you. If you notice, the sentence after that referenced numerous labels that have been approved in the past that do not directly follow the rules that everyone is subject to. Again, considering we have to work with multiple agencies & people that can make us have a good day or a bad day by their decisions, I chose to end my sentence at that instead of calling out folks that may read this forum. However, considering you did choose to take it personally, you bring up a good topic which needs to be addressed.

No one is refuting your vast knowledge of bourbon, whiskey, and the distilling world in general. What we do take exception to is the fact that you brush off Paul's comments as mere "opinions" and "mistaken conclusions". This isn't a debate. This isn't his opinion or conclusion. It's a direct quote from the agency itself.

Since you want people to respect your right to a voice and actually hear (not just read)what you're saying, take a little of your own advice and do the same.

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Tell me why I'm wrong, don't tell me why I have no right to speak.

You have every right to speak, Cowdery, a right which you exercise often. But some distillers here find your posts to be unhelpful, which shouldn't surprise you since you're a journalist, and we're distillers. You can pontificate all you want about how simple TTB regulations are, how helpful TTB agents are, and how easy the COLA process is, but the fact remains, you don't know what you're talking about. I'm sure people on your blog would love to hear about all of these things from you, but your voice on the subject in THIS forum reeks of a lack of experience.

I could just as easily log on to an authors' forum and go on and on about what a simple process it is to write a book and have it picked up by a major publisher. You just write a great book, and start a bidding war between eager publishers, right?

Of course, I'd be speaking without any experience in the matter, and the authors on that website would be wise to ignore my ignorant rantings. Don't be surprised when your recieve the same treatment here.

Telling journalists to shut up and go away tends to be a bad way to promote a product you want the public to trust and buy.

This forum would be a much less interesting place without your lay-opinions injected here and there for our reading pleasure, Cowdery. That being said, I feel obligated to call BS on your whole "the TTB is a wonderland of simple regulations and helpful bureaucrats" thing. It's just not true. I'd hate for someone to actually believe you and then be disappointed with the reality of the situation when they begin the COLA process. I'm not telling you to shut up and go away, I'm just disagreeing with your opinion on the matter and pointing out that you seem to have litle or no experience in the area anyway. In my opinion, more helpful advice would be "COLAs are a nightmare. Be prepared for a long, difficult process. You'll probably want a lawyer."

Nick

P.S. I look forward to discussing this and other issues with you in person and over some bourbon. I find your viewpoints to be very thought-provoking.

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If anyone thinks I'm saying the TTB "is a wonderland of simple regulations and helpful bureaucrats," then I have failed utterly to convey my actual opinion, a failure which is entirely my fault, and for which I apologize. I believe nothing of the kind. I believe the TTB is a federal regulatory agency, perhaps better than some, worse than others, but bearing all of the hallmarks of a federal regulatory agency, which is why I agree with you, Nick, that "COLAs are a nightmare. Be prepared for a long, difficult process. You'll probably want a lawyer." To which I might even add, "or a shotgun."

But just because I am not on the front lines in this regard is not the same as having "little or no experience in the area," but you're entitled to disregard my observations on any basis you wish.

On the other hand, beverage alcohol is a highly regulated industry and you can't work in it for more than 30 years, in any capacity, without getting a pretty good feel for the rules.

If I may offer another piece of unwanted advice, micro-distillers who are frustrated with the TTB might want to look around for someone who has worked in compliance at one of the majors (not necessarily a lawyer), who might be willing to consult. The first thing I do when I'm frustrated with a bureaucracy is find someone who knows more about it than I do.

While I'm on the subject, Buffalo Trace White Dog is officially classified merely as whiskey, as is one of Heaven Hill's Try Box releases. I am assured by both producers that both products spent the minimum amount of time in oak containers to qualify as whiskey. In the case of Try Box Rye Whiskey, the container was new charred oak, as required. The phrase "straight from the still" is what the TTB calls a 'fanciful' descriptor. It was submitted and approved months before the product was released.

But what do I know?

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If you want to sell "White Whiskey" in California there is this from the California Department of Alcoholic Beverage Control.

BUSINESS AND PROFESSIONS CODE SECTION 25170-25178

25175. Any person who sells at retail any potable spirituous liquor

product labeled as whiskey, including blended whiskey and blends of

straight whiskeys, except products containing 20 or more percent of

straight whiskey or whiskeys which have been aged in charred oak

containers for three or more years after distillation and before

bottling is guilty of a misdemeanor, except that this section does

not prohibit the sale at retail of unaged corn whiskey, when so

labeled, or the sale at retail of gins, brandies, rums, cordials,

liqueurs, bitters, or other distilled liquor products, or products

compounded of distilled spirits and other materials, when in no wise

labeled as whiskey or blended whiskey or blends of straight whiskeys,

or the sale at retail of Scotch whiskeys, or spirit whiskeys

containing not less than 5 percent straight whiskey, three years old

or older.

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BUSINESS AND PROFESSIONS CODE SECTION 25170-25178

25175. Any person who sells at retail...

That's funny. Am I reading this correctly that distillers and wholesalers are free to sell whatever they would like as far as this law is concerned, and the poor, misinformed retailer is the only one liable to catch any flack?

Gotta love California.

Nick

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