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Submitting COLA-online for vodka...can't get passed formula


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While trying to submit the COLA online for our vodka, it's preventing me from moving pass the screen where you need to select a formula. I was under the impression you didn't need formula approval for a true to form (no added stuff) vodka. I've gone ahead and submitted a formula for our vodka on formulas online just in case, but this process is a bit confusing. Can someone shed a little light on this?

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TTB is not always clear about what it requires. I’ll try to set the record straight, with the caveat that TTB is the authority, not me.

I think that the problem is that TTB is not very rigorous in explaining this issue. It address the need for formulas for vodka in two places. The first is in the regulations, where it clearly requires a formula. The second is in its comments on the need for pre-COLA evaluation, which means, in practice, the need to submit a formula before getting label approval.

The latter is the source of the reference, above, to a formula not being required unless you ad harmless flavoring, coloring, blending materials. That statement has a limited application. It speaks to the matter of needing a pre-COLA evaluation for Vodka. You do not need a pre-COLA evaluation for vodka unless you add the harmless materials. Therefore, you do not need a formula to get the label approval, or at least you should not need it unless Formulas Online is acting up or programed incorrectly.

WARNING: To remain vodka, the harmless materials added may only be citric acid and sugar and they must be added within the limits prescribed by §5.23. Exceed those limits or add something else – flavored vodka if it fits that standard and a distilled spirits specialty item if it does not.

However, the fact that you do not need a formula to get the label approval does not mean that you do not need a formula for vodka. Generally, you do. The exception is when you produce vodka by original distillation in the production account, i.e., when you declare it vodka, not NSG, at the time of the production gauge. If you declare it NSG, then the further processing required by §5.22(a)(1) to turn it into vodka results in a change of class and type. That requires a formula.

Am I sure of this? Yes I am. The regulation is not at all ambiguous about that. § 5.27(l) provides as follows:

Formulas are required for distilled spirits operations which change the character, composition, class or type of spirits as follows … 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; (3) Mixing with other spirits or with any other substance or material except pure water, after production …

TTB should make this clear in the chart they furnish discussing pre-COLA evaluations and the need, or lack thereof, for formulas to get label approval. They do not. Their silence is confusing and can lead you astray from what §5.27(l) requires. You have to read the regulation with care to find that requirement. TTB should point you in that direction, unless, of course the author of the pre-COLA guidelines didn’t read with the care they expect you to use.

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  • 3 months later...

So, if you were going to produce an infused (Flavored) Vodka from purchased NGS would you:

1. submit a single formula where you take 190 proof NGS, carbon filter or redistill it to create Vodka, then infuse the vodka with your flavoring

2. submit two formulas, one for making Vodka from 190 proof NGS via filtration or redistillation, and another for infusing the vodka with your flavoring

how much detail does TTB require of your NGS --> Vodka process?

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  • 2 weeks later...

As stated, the reason you often need a formula for Vodka is because most people don't produce Vodka directly from fermentation. Instead, they often produce from an intermediate distilled spirit that was not Vodka. In that case, the product has now undergone a change in description of its type, and that requires a formula be submitted and approved. But since you CAN product a Vodka directly from fermentation so that there is no intermediate spirit type, you CAN get a COLA for Vodka that does not require pre-COLA formula approval.

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