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Rays Distilling

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  • 2 weeks later...

To be called Vodka, you do need to make at least one pass through activated carbon. Do it before or after cutting to 80 proof, but you must do it. Coop

No you do not.

Title 27 part 5.22 The standards of identity

(1) “Vodka” is neutral spirits so distilled, or so treated after distillation with charcoal or other materials, as to be without distinctive character, aroma, taste, or color.

This is so basic, I'm astounded at your incorrect response.

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You only need to run it through activate carbon if there are any flavors or aromas that might be interpreted as not meeting the neutral character requirement, or at least to present to TTB as evidence in your process to achieve the same. But it is not required per se.

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You only need to run it through activate carbon if there are any flavors or aromas that might be interpreted as not meeting the neutral character requirement, or at least to present to TTB as evidence in your process to achieve the same. But it is not required per se.

This is also not true. Read the applicable section: "...with charcoal or other materials...". There is no requirement for using activated carbon (charcoal).

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Vodka=" Neutral spirits distilled or treated after distillation with charcoal or other materials so as to be without distinctive character, aroma, taste or color is what it says. " without distinctive character, aroma, taste or color". As far as I know only activated charcoal is the only way to make it meet this requirement. Any thing else would be sure to add color, aroma or taste to the spirits. You make yours your way and I will make mine my way, Aloha, Coop

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Actually, there are other ways, using other filtration beds, but these are far more expensive and exotic than charcoal, and you would likely have to demonstrate to TTB that it works. But if you indicate in your process description for the formulation that you finished with charcoal filtration, you have met the requirement, or at least they are more likely to assume you have done so?

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1. There isn't a formulation requirement for vodka, so that's irrelevant. Send in your label and you're done.

2. The operative portion of the CFR is "so distilled, or so treated" There's no need for filtration of any kind, folks.

3. The whole section on vodka is relative to other spirits. Flavors, odors, etc. are all relative to all the other types of spirits (i.e., everything distilled south of 95%). No vodka is odorless or flavorless. Again, the operative word is "distinctive"... as in when you look at the of the Standard of Identity for, say, whiskey you find, "that the distillate possesses the taste, aroma, and characteristics generally attributed to whiskey". In other words, characteristics distinctive of whiskey.

So when the CFR reads "....as to be without distinctive character, aroma, taste, or color.", what they mean is that it doesn't have the distinctive characteristics of any of the other spirits listed in the Standards of Identity.

4. Happy holidays to my fellow distillers!

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Vodka=" Neutral spirits distilled or treated after distillation with charcoal or other materials so as to be without distinctive character, aroma, taste or color is what it says. " without distinctive character, aroma, taste or color". As far as I know only activated charcoal is the only way to make it meet this requirement. Any thing else would be sure to add color, aroma or taste to the spirits. You make yours your way and I will make mine my way, Aloha, Coop

You are of course free to make your stuff any way you want, but it's never a good idea to tell other people they must do something that is not required. You did not make a suggestion to the OP, you told him he "must do it". I corrected your error.

Denver Distiller has it right, and with festive greetings to boot. Mele Kalikimaka.

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So I need to ask a question in here. Isn't the difference between vodka and neutral spirits the extra step of filtering it? If all you are doing is distilling it to 190 proof then isn't that by definition a neutral spirit? By that logic everclear can also be considered vodka. It's not because it doesn't go through the filtering step.

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By that logic everclear can also be considered vodka. It's not because it doesn't go through the filtering step.

Or could it be considered vodka? — but instead goes with the Everclear brand of neutral grain spirit which carry's a whole lot more [low brow] cache by being labeled "grain alcohol" vs. Vodka? Not trying to delve any deeper into spirit classifications (I've got my hands full with "light whiskey" right now) so I won't offer opinion on the vodka thing, but I've always wondered about that Everclear nonsense, and taken issue with it's destruction of the term "grain". I can't mention grain whiskey around the average person without catching looks of disgust. One way or another, that is some powerful branding on Everclear's part.

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1. There isn't a formulation requirement for vodka, so that's irrelevant. Send in your label and you're done.

True. So caught up with other discussions about formulation with them right now (mostly distilled versus redistilled gin), I forgot that.

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Well I hate to be the one to burst your bubble but David and Denver you are both wrong. I just got off the phone with the labeling and formulations department of the TTB and indeed you must have treated the alcohol that has been distilled to 190 proof with some kind of charcoal in order for it to be called Vodka! which would render the alcohol tasteless, orderless, colorless. The TTB agent then referred me to a Mr. Neil Pennington who is in charge of all spirits testings at the TTB and he confirmed what I was told by the other agent. I then ask him the question of, that distilling of any alcohol to 95% is enough to meet the requirement of being without distinctive character, aroma, taste, or color, and his reply was no. The only way was to distill to 100% as at 95% there is always carryover of organics in the alcohol. The best chance you can get is by distilling the alcohol from corn as it has the fewest organic carry overs but some is still there. The only statement I made that was in error was that you must use activated charcoal as there are other charcoals that will work, but that activated is the most cost effective way to meet the requirement, end of story. Po Ba to me for telling someone what was the most inexpensive way. Aloha and Merry Christmas to you all. Coop

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Well, just to be scientifically accurate, one could do very high plate repeated distillations on a top quality fractionating still, and eventually should be able to get something as pure as you would get from activated charcoal filtration, so long as the contaminating material is not a strong azeotrope with ethanol and water. Most are not. And it would certainly not be a cost effective way of doing this. But perhaps what you heard is what I heard when I was having my discussions about classifications of GNS as base spirits for redistilled gin, because I thought I had heard the same thing somewhere along the line. Yet Denver's point is still nominally correct: unless they test or inquire, how will they know? Without a required formulation, they would not know that you did not charcoal filter, unless you are doing vodka only and your DSP application does not include filtration in the process description? And I fear if they did inquire it would just come down to this: if you did filter, they would leave you alone, but if you did not and there was any reason to suspect you did not meet the requirement, they could just say you didn't meet it. Hmmm...

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Funny thing is, when I asked about filtration of both Gin and Vodka, I was told at their Cincinnati office in 2001 that you specifically don't have to filter either.. since that was of particular interest to me, as a brewer who made unfiltered beers. The read the same passage to me that I cited to you.

Happy Holidays to you, Coop!

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I know what you are talking about. I think we all had a discussion a while back on questions about ttb rules. You never seam to get the same answer twice in a row as you can never speak to the same person. Like label approvals, one says its ok and the next person wants changes made. I would like to stop by next time I am in Denver. Coop

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Well, just to be scientifically accurate, one could do very high plate repeated distillations on a top quality fractionating still, and eventually should be able to get something as pure as you would get from activated charcoal filtration, so long as the contaminating material is not a strong azeotrope with ethanol and water. Most are not. And it would certainly not be a cost effective way of doing this. But perhaps what you heard is what I heard when I was having my discussions about classifications of GNS as base spirits for redistilled gin, because I thought I had heard the same thing somewhere along the line. Yet Denver's point is still nominally correct: unless they test or inquire, how will they know? Without a required formulation, they would not know that you did not charcoal filter, unless you are doing vodka only and your DSP application does not include filtration in the process description? And I fear if they did inquire it would just come down to this: if you did filter, they would leave you alone, but if you did not and there was any reason to suspect you did not meet the requirement, they could just say you didn't meet it. Hmmm...

Bluestar I am not even sure that you could get to 100% with distillation process only. Rubbing alcohol the highest I have ever seen is 99.9%. But to get that I think they have to add something to our type alcohol which gathers up all the other leftovers and then it is remove by a chemical process. Activated carbon will not improve proof of alcohol, it just removes other things. I have never seen a rise in proof even after 6 passes through activated carbon. As a distiller you are expected to have some knowledge of the requirements. If you are going to do something different they you have to ask permission. They expect you to call them if you have or need clarification. Also they can and will say more than Hmmmm. They can fine you, require that you recall all of your product. Known as a "product recall", and suspend your license all of these are bad.

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Once again, the devil is in the details and the rule for vodka is very clear. Crystal clear, you might say. One sentence seems to cause so much confusion? I do not doubt different responses are received from the TTB about this, and every other, question. The answer you were just given is wrong, or has been misunderstood. But this doesn't even warrant a question. Sure, distilling to 95% is not enough to qualify as vodka, just like the one sentence rule says. Also like the one sentence rule says, charcoal is not required. At all. What does "so distilled, or so treated after distillation" and "with charcoal or other materials" mean? (emphasis mine) Exactly what it says. There is no ambiguity regarding production requirements. There is some ambiguity regarding what constitutes "without distinctive character, aroma, taste, or color" , but that is not the issue of this thread.

I stand by my previous comments: use it or lose it, charcoal is up to you. And as was mentioned previously, there is no formula requirement for vodka, so asking the TTB how one should filter it is a nonissue.

But I have not really addressed Ray's initial questions directly. You asked "what do I need to do to finish my spirit and bring it down to an 80 proof vodka?" This cannot be answered satisfactorily without knowing more about how you plan to produce the neutral spirit, and what water you are using. It could indeed be as simple as blending the neutral together with water, everything depends upon the quality of those two ingredients and if the final product meets the (admittedly flexible) requirement of being without distinctive character, taste, aroma, or color. I suspect, however, that you are looking for the standard production method. Coop is right that most producers run the 80 proof through granular activated carbon as a simple, inexpensive method to remove unwanted congeners. Search this forum for "activated carbon filtering" or some such variant and you will find information for that. Basically you will need a vessel to hold that carbon, a pump to move it through the carbon (or just use gravity, though that's really slow), and some type of final filter (plate, cartridge, bag) to remove any particulates from the vodka. Personally I don't do that, nor do some notable others, which is the whole point of my contrarian posts.

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  • 3 weeks later...

Thanks all...timely topic to me. I have a further finishing question for vodka though.

We plan to filter with either charcoal or another substance (we live next to the Herkimer "diamond" mine so we may go local). My question is: we blend to proof, chill to filter, then do you folks warm to a certain temperature before bottling? and if so how; open air tank, warmer? Thanks.

Steve Cox

Adirondack Distilling Company

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You probably want to blend to slightly above proof, as filtering may lower your alcohol by volume. You'll want to adjust at the end, and take the time to allow the ABV and temperature to stabilize so you can get an accurate reading. Check 27 CFR for information on the tolerances that are allowed.

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