COLA and Recipes

[jim.mccollom]

We are currently in the process of getting our TTB site approval and would like to have our COLA pre-applications done at the same time if possible. While looking through the process, it seems that there are 3 steps we need to go through for a distilled spirit:

1) Laboratory Analysis - This one seems to be the real point of contention, because in order to submit a sample, it seems we need to have our site approved in order to begin production of the spirits; which precludes us from getting the pre-applications done before we have our site license. Is this the case ?

2) Formula Submission - We intend on submitting an application for gin, however we are not sure of ratios at this point. Is it necessary to have the final proportions of the ingredients nailed down before submitting the formula, or is there a bit of flexibility to vary the amount of a particular ingredient after submission of this form ? Is this necessary for simple spirits, like vodka and bourbon ?

3) Sulphite Analysis - Is this necessary for distilled spirits ?

Have I missed any steps or assumed any unnecessary steps in the pre-approval process ?

Additionally, what is the current timeline for getting a product through pre-approval and final approval (assuming there were no problems with the submission) ?

Thanks for your help.

Jim McCollom

[Ralph at Tuthilltown]

Some brief answers, subject to confirmation by the TTB.

There is no reason I know of which requires you to have product before having a facility to make it in. You can seek out some other distiller to produce your formula, work out the kinks and get your sample. This only means that particular formula and the contents of that particicular batch are approved, if anything changes you'll have to resubmit.

For Gin or any manipulated neutral spirit you must submit a "quantitative list of ingredients", that is the total amount of all the things you added to the starting base neutral spirit; and it must include the Latin name of any organics, herbs, fruit, grains, whatever you put in must be identified with the percentage of the volume noted. READ THE APPLICATION and the Law.

Call the TTB about the Sulfite question.

But all these questions could have been answered by a careful read of the Law and the pertinent regulations. Before submitting any further questions, READ THE LAW.

[Paul]

Ralph:

I had asked Jim to post the question in order to get some advice from those who have already been through this process, because THE LAW IS SOMETIMES CONFUSING. In fact it should have been apparent from his question that he had READ THE LAW but wanted to make sure we were interpreting it correctly.

Using all caps in an email is akin to shouting and was not really appropriate in this situation where a question was politely asked.

I'll just assume that you must have missed your coffee this morning.

Best Regards,

Paul McCollom

[kkbodine]

If you have not done so already, go to the TTB website and download a copy of the Beverage Alcohol Manual (volume 2 Spirits), http://www.ttb.gov/spirits/bam.shtml. It has a lot of great information regarding labeling, additives, standards of identity et al that you will want to know.

Also, check out:

http://www.ttb.gov/industry_circulars/arch...val_spirits.pdf

Cheers,

Keith

[Paul]

Thanks Keith, will do, appreciate the guidance. Possibly only 4 months away from our equipment

Best,

Paul

[jim.mccollom]

Thank you for your replies. I had read through the law and thought as much, but I figured I would double check here before I started hiring an external firm to handle distilling the sample first.

Jim McCollom

[Denver Distiller]

This little tip will save you a wad of dough:

You don't need to send in samples for the nearly all spirits made by a licensed DSP (assuming this will be you). In fact, most DSP released spirits don't even need formula approval. Vodka, Gin, Brandy, and Whiskey (most of 'em) just need COLA's, and that's it.

Do yourself a favor and drive/fly yourself to the nearest TTB office. Cinnci, DC, whatever. Sit and meet with the agents. Ask tons of questions, and go over every step of your plans. They are there to help you. It'll save you thousands of both dollars and hours of waste.

Here's a link to the TTB chart which shows which SOI's require lab analysis or formula approval:

http://www.ttb.gov/industry_circulars/arch...mdsp6-27-02.pdf

[Classick]

This little tip will save you a wad of dough:

You don't need to send in samples for the nearly all spirits made by a licensed DSP (assuming this will be you). In fact, most DSP released spirits don't even need formula approval. Vodka, Gin, Brandy, and Whiskey (most of 'em) just need COLA's, and that's it.

Do yourself a favor and drive/fly yourself to the nearest TTB office. Cinnci, DC, whatever. Sit and meet with the agents. Ask tons of questions, and go over every step of your plans. They are there to help you. It'll save you thousands of both dollars and hours of waste.

Here's a link to the TTB chart which shows which SOI's require lab analysis or formula approval:

http://www.ttb.gov/industry_circulars/arch...mdsp6-27-02.pdf

this is a very important point... also.. make sure you get a document stating that you DONT need formula approval for said spirits, so that you may submit a copy of that along with the COLA.

Everytime i apply for a new grappa label, they reject it saying i need formula approval, and every time i send it back with the document say... oh no i dont, heres proof!