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Trouble with Aged Aquavit COLA


StonesRyan

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Anyone out there have any experience with a COLA for aged gin or aquavit that can help shed some light on COLA's? I've submitted a COLA with verbiage on the back of the label that stated "the golden color is the result of time spent maturing in charred oak barrels". That version was kicked back and I was told to remove the word "maturing". That makes sense, I guess. I made the requested change and resubmitted only to have TTB now tell me I have to remove the whole sentence in it's entirety because they say it's an age statement. When I point out that it's in direct reference to the color specifically they insisted it's still an age statement. Exactly how do they define an age statement? They claim to not allow the words aged, matured, etc so as not to mislead consumers yet it undergoes the same exact process within the barrel as whiskey does but somehow it's misleading to call both spirits "aged"? I disagree with TTB on this but I can live with that as it's what is stated in the CFR. What I can't understand is the idea that specifically referencing the color of the spirit is somehow also an age reference. The agent I spoke with suggested that I say "the color is the result of time well spent". That doesn't make any sense and it's not even a complete sentence yet somehow according to TTB it's not misleading while the added clarification of "in oak barrels" is. Any suggestions of how I can convey my message while appeasing TTB?

On a sidenote, the TTB agent I spoke with also argued with me that aquavit isn't traditionally aged yet Linie, and others, have been doing it for a couple hundred years at least. So how long must something be done in order for TTB to consider it "traditional"?

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And different reviewers will give you different results. We have a few of our products identified as "Barrel Reserve", no problem. And some gins were even described on back label has having been stored in oak barrels, with no period of time. That is not an age statement. But later, other requests were not approved with same same verbiage.

These rules are fairly modern, pushed by the whiskey makers, so they don't recognize the historical existence of aged gins and aquavits. We should get these changed to simply allow an age statement, and keep it simple, the same as brandy or rum.

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@Skaalvenn, that's funny! Whatever works!

@bluestar, for the back of the label I was told by TTB via email that I could use "The golden color comes as the result of being stored in charred oak barrels". Despite being pre-approved, it was declined. I'd previously submitted "The golden color comes as the result of time spent in charred oak barrels" and "The golden color comes as the result of time spent maturing in charred oak barrels", both of which were also declined. TTB is still saying these are "age statements" and are misleading which has me entry frustrated as the statement is in direct reference to the cause of color rather than age. Anyway, I'm with you regarding getting this regulation changed to be more inclusive of any spirit that's been aged as they all undergo the same changes within the barrel so anything short of calling it what it is is what's misleading to the consumer. How do we go about getting something like this changed? Most of us little guys don't have the lobbying power, or money, to compete with the big whiskey makers unless we were able to convince ADI or ACSA to take it on on the behalf of us all. I fear they have their hands full with the FET reduction currently and perhaps there are a lot of small whiskey producers that would be against such a change anyway. I'm on board if you have any suggestions or ideas to get something like this moving!

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I could see "time spent" being a problematic phrase, because it suggests "aging" even though no specific time is mentioned. "Stored" is a little less problematic, and what I have seen approved in some cases before, but not always, including for myself. I have lost track of whether this discussion you have had with the TTB was for gin or for aquavit. For the former, there is an explicit requirement that there be no age statement, so they are sometimes stricter about phrasing with gins than for other spirits.

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Hey Bluestar, I'm working on an aged aquavit label but have found that they're just as strict with it as with aged gins. My greatest frustration stems from their inconsistency with regard to enforcement which causes unfair advantages for those fortunate enough to get a prohibited label approved.

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