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NGS Formula approval


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For purposes of the standards of identity,neutral spirits is a class and vodka is a type of neutral spirits. If you do not designate the origin al distillate as vodka when you make the production gauge, which you can do, but which few do, an d instead call the distillate neutral spirits, then you must do something to the spirits you have designated as neutral to convert them to vodka. If you are thinking, "If persons can designate half a distillation run of a neutral distillate (190 and above) as vodka and need do nothing more to it to sell it as vodka, why would that person need to do anything at all to the other half of the run to make the claim vodka, since the spirits are the same - you are asking one of those questions that have no logical answer.

In the case you propose, if the distiller from whom you buy the spirits designates it as vodka,then you would not have to do anything to it, but the catch is that you would not then be the producer and your mandatory name and address on the label could only state "Bottled by MaskCraft," which is a red flag that you did nothing at all to it. So you will buy neutral spirits and convert them to vodka in the production account by either, (1) redistilling them (in which case you may state "Distilled and Bottled by MaskCraft) or filtering them (in which case you may claim "Produced and bottled by MaskCraft).

Here is what the regulations say:

§5.27 Formulas.

Formulas are required for distilled spirits operations which change the character, composition, class or type of spirits as follows:(l) The production of vodka by—

(1) Treatment of neutral spirits with not less than one ounce of activated carbon per 100 wine gallons of spirits;

(2) Redistillation of pure spirits so as to be without distinctive character, aroma, taste, or color;

That is straight forward. However, you do not need to submit a formula to get approval for a vodka label unless you add harmless coloring, flavoring or blending materials. Such additions are limited by Section 5.23 to sugar and citric acid within the limits prescribed by that section - see http://www.ttb.gov/industry_circulars/archives/2007/pre-cola_eval_spirits.pdf, for the complete list of products requiring precola evaluations. But do not misinterpret this to mean that a formula is not required to make vodka out of neutral spirits. Under 5.27 a formula is required to do it, but you need not submit the formula with the application for label approval. Now, before taking my word as gospel on this, even with the citations I offer, ask TTB to affirm your understanding.

Here are my rules for asking questions of TTB. First, if possible, know the answer before you ask, which allows you to argue with bad answers. Second, even if you think you know the answer, ask TTB to confirm your understanding. Third, if it is really important and if the answer they gave is not in writing, after they have answered, send an email stating that you would like them to confirm what they told you orally and save that response.


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