Gin COLA

[nick jones]

I'm in the process of developing a gin (a dry gin, not a compound gin) and I'm getting to that wonderful spot where I need to think of a COLA and (possibly) a formulation.

Near as I can tell, this is what the CFR has to say about gin formulas:

27CFR 5.27 - Formulas are required for distilled spirits operations which change the character, composition, class or type of spirits as follows:

(j) the production of gin by-

(1) Redistillation over juniper berries and other natural aromatics, or the extracted oils of such, of spirits distilled at or above 190 degrees of proof, free from impurities, including spirits of such a nature recovered by redistillation of imperfect gin spirits...

This seems to say that the only gin that would not require a formula would be one that was only distilled once, where the botanicals were added to the mash. Does anyone out there make gin this way?

Do those of you who produce (or buy) neutral spirits to redistill with botanicals into dry gins all have formulas for your gins?

I've never submitted a formula to the TTB before and I'm a little intimidated by the prospect. Do I just need to get over it and get going on a formula? If so, any advice on what to say or not to say to the TTB in the formula?

Thanks for the help,

Nick

[Paul Tomaszewski]

Well the good news is if you submit your formula using COLAS/Formulas Online, the turnaround time for formulas is a day or two vs. COLAs being a month or more. The Formulas Online can be a little tricky getting used to the first time, so probably not a bad skill to get knocked out. Not sure why they made Formulas Online so different in the setup and use of it vs. COLAs online.

[KBFreeRange]

Nick,

If you are using the online method of submission your formula and statement of process will need to be approved by Formulas Online before you can submit for your label approval. The documents are tricky, and the site is engineered to run on Explorer 7, which may render some of the functions you are trying to perform during correction of your documentation difficult to do. Once you get your formula approved by Formulas Online you can submit your label materials for approval by COLAs Online. Our experience has not been that this takes a few days, rather 3-4 weeks for each submission. TTB promises an initial response within 45 days. All in all it takes almost the same amount of time to file via mail, in my opinion.

[hawk]

Hi,

We went through this with TTB a few months ago. The overview is that both we and the TTB seemed to find this topic VERY confusing. We got bumped up to a 'technical expert,' who had several different answers over the course of two days as he read and re-read and consulted others.

However, the final answer we got was that we did NOT need to submit a gin formula, either for our NGS-based gin or the one we make with alcohol from our apple cider. The explanation: "You're not redistilling gin; what you're making is gin for the first time when you make it."

Hawk

[delaware_phoenix]

If your gin is a fairly classic or standard gin, it probably doesn't need a formula as you are using standard botanicals used in gin for a long time. You might want to check your botanicals against the GRAS list just to be sure. But just because it's not on GRAS doesn't mean that it's not Generally Recognized As Safe (arrowroot is an example). Duke Univ. has a nice list. http://www.ars-grin.gov/duke/syllabus/gras.htm

[bluestar]

In fact, there are a great many common native botanicals that have been used in the USA for centuries, and even earlier by native Americans, that are not on the list. Some are regularly sold in food products (spicebush berry), others are commonly found in packaged teas (anise hyssop), and others are parts or forms of the plant otherwise on the GRAS list (prickley ash berry). Why many of these are not on GRAS probably relates more to their not having been adopted by commercial food producers in the 20th century, rather than any safety issue.

[bluestar]

Hi,

We went through this with TTB a few months ago. The overview is that both we and the TTB seemed to find this topic VERY confusing. We got bumped up to a 'technical expert,' who had several different answers over the course of two days as he read and re-read and consulted others.

However, the final answer we got was that we did NOT need to submit a gin formula, either for our NGS-based gin or the one we make with alcohol from our apple cider. The explanation: "You're not redistilling gin; what you're making is gin for the first time when you make it."

Hawk

See my other thread on Gin formulation in the Gin area. My most recent correspondence from the TTB (quoted there) states definitively that distilled versus redistilled is precisely whether there is one or more distillations from the mash, as the original post (Nick Jones) suggested. I know that is not consistent with other info obtained from TTB nor with how many currently submit to COLA. And I don't think it makes any historical sense either, since I believe the formulation requirement IS NOT driven by review or determination of botanicals (other than juniper dominance) since that was historically an FDA issue. Rather, I think it may have derived from the concern for "adulteration" or masking poor quality of gin products by a blender or rectifier, versus product of a distiller. If so, then the interpretation suggested by Hawk would be appropriate. I think there is enough confusion on this topic that the TTB really should issue a clarifying statement or bulletin.

[bluestar]

An update: the CFR language that requires the formulation is the part about changing class. That is why if you have something that starts as a spirit in another class, then you redistill it to make it a gin, it requires a formula submission. And that's why I suspect sometimes they allowed multiple distillation gins to NOT be considered redistilled, if the product was never classified as something else in the interim. For example, if you distill low wines to later redistill and barrel age to make a whiskey, it is not considered a change in class, and no formulation is necessary. One could argue the same for a gin. They key is never to have classified it as anything else in the interim. But I don't think that is how the TTB is currently viewing it. Anyone have any recent example to the contrary? All recent presentations from TTB seem to indicate the stricter interpretation is in force.