Formula Modification?

[TNJustin]

Is it possible to make a change to an approved ttb formula? For example: adding a small amount of sodium hydroxide to balance the pH of an existing product, or changing the bottling proof? I know the formulas allow some leeway in terms of how much of each ingredient is put in, but what if I would like to change something more than that? do I have to submit a totally new formula?

[Distiller76]

Are you adding the NaOH to the finished product, Or in the Mash? If it's in the mash, No, Being as it's fermentation support. If it's going in the finished product.. That's a different story, And would need to be listed on the bottle as well.

This might be helpful,

http://www.ttb.gov/labeling/allowable_revisions.shtml

[TNJustin]

I've looked at that page, but I've only found where it addresses label changes, not formula changes. The NaOH is in reference to a flavored spirit, I need to drop the pH to keep the color we use from fading. We've used it in a couple other products and it's not listed on the label, we had no problems with approval there, can you point me to where it says that should be disclosed?

[bluestar]

You MIGHT have to add it to the formula, but that is because the TTB has been shifting their expectations for formulas. It used to be that items put into the mash for fermentation support, such as the yeast, nutrients, pH adjustment, etc., did not have to be in the formula, although expected to be mentioned in the process. The current officer in charge of formula evaluation stated to me over the phone, after recently sending back a formula that was almost verbatim of a type I had had approved on multiple occasions, that while not needed in the past, items like yeast, nutrients, and WATER had to be included in the OTHER category. Any ingredient introduced as part of the process needs to be in the list, supposedly.

[TNJustin]

I guess what I'm asking is can I modify an approved formula without starting over from scratch? I don't mind adding something, but I don't want to have to redo the corresponding COLA or wait the two month approval time.

[bluestar]

I guess what I'm asking is can I modify an approved formula without starting over from scratch? I don't mind adding something, but I don't want to have to redo the corresponding COLA or wait the two month approval time.

I think you are stuck. You change the formula, your COLA is for the old formula, you have to do the COLA for the new formula. DADT