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Neutral Brandy or just Brandy


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I've been discussing this topic with a couple of other local distilleries in my area, and the comments are contrary to my understanding.

My question is this. If I distill my wine to +170proof, do I have to call the product Neutral Brandy or can I still just call it Brandy, especially since there is considerable character still in the distillate?

My understanding is I have to call it Neutral Brandy, but I've been told by other destillers to interpret the regs as not saying "have to" , but instead saying "able to".

So my 172proof Grappa run can be called Grappa, and not have to be called Neutral Grappa. And my 171proof Brandy run can be called Brandy and doesn't have to be called Neutral Brandy?

BTW: These are all runs we did early in the game, before we became aware of the delicious brandy coming off at lower proof runs.

Thanks for the insight.

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You don't have to call it neutral brandy, and in fact I don't believe you could call it neutral as it's not distilled to 190. Per standards of identity "Brandy" is

Spirits distilled from the fermented
juice, mash or wine of fruit or from its
residue at less than 95% alcohol by
volume (190 proof) having the taste,
aroma and characteristics generally
attributed to brandy and bottled at
not less than 40% alcohol by volume

(80 proof

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from the BAM for neutral brandy : Any type of brandy, e.g., “Fruit Brandy,” “Residue Brandy,” etc., distilled at more than 85% alcohol by volume (170 proof) but less than 95% alcohol by volume (190 proof)

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