Jack Daniel's Rye is now "spirits distilled from grain."

[cowdery]

The new Jack Daniel's Tennessee Rye, originally (and incorrectly) classed as 'neutral spirits,' is in the marketplace now and classified as 'spirits distilled from grain.' More here.

I post this as guidance for anyone struggling to get an approved label for an 'unaged whiskey,' since they won't let you call it whiskey.

[jwymore]

With the number of craft guys doing un-aged (whiskey) it seems like we may need a new category added to the definitions. Until then the word whiskey is taboo .... Specialty makes way more sense than neutral though!! Thanks for posting the revision ....

This begs the question ..... If i put it in a barrel for a day is it then whiskey?

[Jedd Haas]

This begs the question ..... If i put it in a barrel for a day is it then whiskey?

Do a search for a very entertaining post by Ralph from Tuthilltown on continuous bourbon processing.

[bluestar]

This begs the question ..... If i put it in a barrel for a day is it then whiskey?

YES. Or ten seconds. No time limit. They should change that.

[bluestar]

I post this as guidance for anyone struggling to get an approved label for an 'unaged whiskey,' since they won't let you call it whiskey.

Except corn whiskey, of course.

[cowdery]

It is not as easy as some people seem to think it is (or should be) to get TTB to change a rule or write a new one. It's very hard and takes a very long time.

[Charles@AEppelTreow]

It is not as easy as some people seem to think it is (or should be) to get TTB to change a rule or write a new one. It's very hard and takes a very long time.

And that's for rules where they have some interpretive wiggle room. Sometimes they (and we) are stuck with the underlying law. So you have to go to Congress for a change.

[cowdery]

Even other arms of the government have trouble getting TTB to move. The Office of the U.S. Trade Representative has negotiated a treaty with Brazil in which they recognize bourbon and Tennessee whiskey as distinctive products of the U.S. and we recognize Cachaça as a distinctive product of Brazil. TTB is only willing to recognize Cachaça as a type of rum distinctive to Brazil, but it has taken years to get that far.

[Ralph at Tuthilltown]

These points were made to the TTB Staff at the recent DISCUS LEGISLATIVE CONFERENCE in DC. The TTB agreed the Standards of Identity need updating, but they may not introduce that change it must come from a petition for change. Unfortunately there is no "form" for such a petition. It must be composed with the best explanation of the justification. As Chuck points out, it is a long process. That does not argue for continuation of inaccurate definitions, many of which handcuff creative new distillers' innovation. While it is true that the law specifies no time limit, the actual text of the Standards of Identity is less than exact, the definition of "whiskey" reads: Class 2; whisky. “Whisky” is an alcoholic distillate from a fermented mash of grain produced at less than 190° proof in such manner that the distillate possesses the taste, aroma, and characteristics generally attributed to whisky, stored in oak containers", the argument has been made that whiskey put into a barrel overnight would not take on the "taste, aroma, and characteristics generally attributed to whisky", but that is a subjective call and the TTB has not enforced it. The argument could be made that the requirement for typical "whiskey-ness" characteristics comes before the requirement that it be stored in oak containers, so the "taste, aroma and characteristics" would be generally attributed to the raw spirit, unoaked. Regardless the strength of the arguments, the distillers in the meeting strongly requested the TTB make some decision on this matter. But the action must be taken by a DSP in the form of a petition. That petition, if launched, should apply to the entire STANDARDS OF IDENTITY, and not just the issue of oaked or unoaked whiskeys. It will be a long and difficult process, but it should begin.

[bluestar]

What undercuts the oak flavoring requirement as part of what is the "taste, aroma, and characteristics generally attributed to whisky" is that corn whisky is also part of the category, and corn whiskey does not have to be aged. Moreover, some of the lesser whiskey categories can be stored in used oak, and if heavily used, may impart almost no flavor from wood. Hence, a good argument can be made that wood flavor is not a prerequisite for "taste, aroma, and characteristics generally attributed to whisky".

[nabtastic]

All good points. I can't honestly decide which side that I'm on, but agree that the TTB has a lot of work to do. Since we are on the Craft Bourbon trail we have a lot of misinformed enthusiast, especially regarding aging requirements. It's amazingly difficult to convince someone that the popularly concieved notions of aging are wrong - or at least not right.

They also need to get together and figure out some rules on tastings and tours. The last question I asked was regarding multiple tours in a given time period (since we are restricted on quanitity sales per tour). The agent responded with "I don't know."

also, is there no spell check on here??

[bluestar]

Can you elaborate? TTB restriction on tours? Sales during the tour? In the distillery? My understanding is there are no retail sales in the distillery proper, bonded premise or general premise. Tastings can sometimes be managed as part of an educational activity, but not as part of retailing, and in this sense a tour might be considered an educational activity. Tasting for retailing should be in retail area, outside of distillery. Although I have been to events where a tasting is in the distillery, and the retail sales are outside of the distillery, and nominally these two are treated as "independent".

[nabtastic]

Hmm, ok.. we are not "in the distillery" as in, physically inside of the bonded area. Our tasting/gift shop is in the building adjacent to us. When I said in the distillery I was referring to the property that we own - not in the room that we are physically distilling in..