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'Whiskey' or 'Spirit'???


paul@mbroland.com

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I know that we have hit on this to some degree in other postings, but maybe we can put this (white) dog to rest with a discussion about our experiences with the TTB. I have been back and forth with formulation on the topic of unaged grain distillate. And, based on what they have told me, to include my latest formula approval, it seems that an unaged grain spirit (that has never touched the inside of an 'oak container') that does not fulfill the criteria of a corn whiskey (at least 80% corn, and if aged must be aged in used, charred or toasted oak, distilled at or below 160 proof) is a spirit and is NOT a whiskey until it goes into the barrel.

For example, if you make a grain distillate that is made of 100% malted barley, distilled at or below 160 proof, and then is bottled at 80 proof or above, it would be "spirits distilled from grain" (and, in this case, you could also use "spirits distilled from malted barley"). Based on what the regs say, this does make sense to me and I am favoring that conclusion. However, in discussing this with other sources who have had similar discussions with formulation, I'm being told that they are able to use the term "whiskey" on the label after submitting a similar formula and it too is an unaged product. If you have had any experience with TTB ALFD Formulation personnel and have heard either way, please let me/us know your experience as I would like to try to ensure that all of us are understanding this correctly, specifically if we make an unaged grain distillate.

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As I remember, there are those on here who are simply passing the spirit through the barrel for a few hours, satisfying the 'whiskey' requirement. Not be labeled as White Whiskey' since there aren't any allowances for that label in the regs, however, since it satisfies the whiskey regs it does allow for a 'Whiskey' label once they pass it through the barrel.

QUESTION--What are you trying to sell, spirits or whiskey?

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For this product, I'm selling a white dog, don't really care about the technical name, obviously I'm going with what formulation has told me (spirits distilled from grain). However, I'm mainly just curious if others have had different responses to this same formula-type in their experience with this matter.

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