Georgeous Posted February 6, 2018 Share Posted February 6, 2018 So I want to release a white whiskey, I submit my label to ttb and they come back with: Your product requires an age statement to appear on your label. It must include the length of time in one of the following formats: 4 years old; 6 months old; Aged 4 years; Aged at least 4 years; Aged a minimum of 6 months; Over 2 years old; Aged not less than 2 years; 60% whisky aged 4 years; 70% whisky aged 2 years. 27 CFR 5.40 I want it to be a white whiskey shine product I don't want to age it, that takes away from the point. I cant call it corn whiskey as it is less than 80% corn in mash how do I address this? Link to comment Share on other sites More sharing options...
bluefish_dist Posted February 6, 2018 Share Posted February 6, 2018 Call it something else other than whiskey and submit a formula under distilled spirit specialty. Unless it's corn whisky it has to be aged to be called whiskey and if aged less than 4 years requires an age statement as you found out. Link to comment Share on other sites More sharing options...
Huffy2k Posted February 6, 2018 Share Posted February 6, 2018 Find some used barrels, age it for one day. It'll still be clear and you can legally call it whiskey (whiskey made from a bourbon mash). 1 Link to comment Share on other sites More sharing options...
Georgeous Posted February 6, 2018 Author Share Posted February 6, 2018 11 hours ago, bluefish_dist said: Call it something else other than whiskey and submit a formula under distilled spirit specialty. Unless it's corn whisky it has to be aged to be called whiskey and if aged less than 4 years requires an age statement as you found out. See below, house spirits white dog whisky , they don't show an age statement on their bottle, how do they get away with it? Link to comment Share on other sites More sharing options...
Georgeous Posted February 6, 2018 Author Share Posted February 6, 2018 6 hours ago, Huffy2k said: Find some used barrels, age it for one day. It'll still be clear and you can legally call it whiskey (whiskey made from a bourbon mash). so what would I put on the age statement in that case? Aged 1 day ? 1 Link to comment Share on other sites More sharing options...
Huffy2k Posted February 6, 2018 Share Posted February 6, 2018 1 hour ago, Georgeous said: so what would I put on the age statement in that case? Aged 1 day ? Correct Link to comment Share on other sites More sharing options...
Silk City Distillers Posted February 6, 2018 Share Posted February 6, 2018 Something to keep in mind, just generally, not specifically about the label posted above. Just because someone managed to get a label through approval doesn't mean it's the label is correct, following regulations, is not misleading, etc. It also doesn't mean that what a distiller put in the bottle, matches what the label expected to be put in the bottle. There are plenty of misleading labels that don't follow regulations. 1 1 Link to comment Share on other sites More sharing options...
bluefish_dist Posted February 6, 2018 Share Posted February 6, 2018 I have seen a few whiskeys that don't have age statements and they are under 4 years aged. That doesn't mean it's right. It just means no one has caught it. If you want it to be whiskey and be white, put something like aged 1 day and then always age it more than 24 hrs. You are covered. My whiskey and bourbon labels were approved without an age statement as they do not require one if aged over 4 years. I added one as we are selling bottles that were aged less than 4 years. Link to comment Share on other sites More sharing options...
JustAndy Posted February 6, 2018 Share Posted February 6, 2018 The House Spirits example was also approved probably 10+ years ago, so there has probably been some turn-over and clarifications to the approval process. Link to comment Share on other sites More sharing options...
jackb1050 Posted February 6, 2018 Share Posted February 6, 2018 If you don't put an age statement on the label , COLA assumes it is 4 years or older. So they pass it until they find out otherwise. Link to comment Share on other sites More sharing options...
Georgeous Posted February 6, 2018 Author Share Posted February 6, 2018 3 hours ago, bluefish_dist said: I have seen a few whiskeys that don't have age statements and they are under 4 years aged. That doesn't mean it's right. It just means no one has caught it. If you want it to be whiskey and be white, put something like aged 1 day and then always age it more than 24 hrs. You are covered. My whiskey and bourbon labels were approved without an age statement as they do not require one if aged over 4 years. I added one as we are selling bottles that were aged less than 4 years. So does sticking a stave in my blending barrel for a day count as aged 1 day? Link to comment Share on other sites More sharing options...
Silk City Distillers Posted February 6, 2018 Share Posted February 6, 2018 No. Link to comment Share on other sites More sharing options...
Georgeous Posted February 7, 2018 Author Share Posted February 7, 2018 23 hours ago, Silk City Distillers said: No. why not? I just spoke with ttb and they told me if I poured through a trough from one vessel to another it has touched oak and I can put an age statement on it. She recommended aged less than 1 minute. So what would be different of a trough or a stave for that matter? Hell what about an oak stir stick my wife calls a mop handle? 1 Link to comment Share on other sites More sharing options...
kkbodine Posted February 7, 2018 Share Posted February 7, 2018 58 minutes ago, Georgeous said: why not? I just spoke with ttb and they told me if I poured through a trough from one vessel to another it has touched oak and I can put an age statement on it. She recommended aged less than 1 minute. So what would be different of a trough or a stave for that matter? Hell what about an oak stir stick my wife calls a mop handle? That answer from the TTB makes no sense and seems like a very loose interpretation of the word "aging". Link to comment Share on other sites More sharing options...
jackb1050 Posted February 7, 2018 Share Posted February 7, 2018 vessel/ container is different than a stick read the standard "oak container" 1 Link to comment Share on other sites More sharing options...
Georgeous Posted February 8, 2018 Author Share Posted February 8, 2018 3 hours ago, jackb1050 said: vessel/ container is different than a stick read the standard "oak container" so why is it ok to run it through a oak trough and say aged Link to comment Share on other sites More sharing options...
Tom Lenerz Posted February 8, 2018 Share Posted February 8, 2018 35 minutes ago, Georgeous said: so why is it ok to run it through a oak trough and say aged It’s not, read the CFR. Link to comment Share on other sites More sharing options...
Georgeous Posted February 8, 2018 Author Share Posted February 8, 2018 so filling a used oak barrel then emptying it is ok? I don't get these regulations Link to comment Share on other sites More sharing options...
Tom Lenerz Posted February 8, 2018 Share Posted February 8, 2018 Yes, read the CFR... https://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=3e62d2aa84281f69f653de44f5e52f81&mc=true&n=sp27.1.5.c&r=SUBPART&ty=HTML#se27.1.5_122 If you don't meet the requirements for corn whiskey below, then you have to meet the requirements of some other whiskey. Likely you will want to use 'whiskey distilled from..." (ii) “Corn whisky” is whisky produced at not exceeding 160° proof from a fermented mash of not less than 80 percent corn grain, and if stored in oak containers stored at not more than 125° proof in used or uncharred new oak containers and not subjected in any manner to treatment with charred wood; and also includes mixtures of such whisky. (2) “Whisky distilled from bourbon (rye, wheat, malt, or rye malt) mash” is whisky produced in the United States at not exceeding 160° proof from a fermented mash of not less than 51 percent corn, rye, wheat, malted barley, or malted rye grain, respectively, and stored in used oak containers; and also includes mixtures of such whiskies of the same type. Whisky conforming to the standard of identity for corn whisky must be designated corn whisky. You will notice it says stored in used oak containers, no minimum age is stated, but age statements are required for less than 4 years of age on all whiskeys. And before you say 'it says container, not barrel', an oak container is a barrel. Link to comment Share on other sites More sharing options...
MGL Posted February 8, 2018 Share Posted February 8, 2018 2 hours ago, Georgeous said: so filling a used oak barrel then emptying it is ok? I don't get these regulations i am not attempting to be rude but you need to "get" these regulations, comply, and, understand them completely if you want to stay in business. Link to comment Share on other sites More sharing options...
Georgeous Posted February 8, 2018 Author Share Posted February 8, 2018 4 hours ago, MGL said: i am not attempting to be rude but you need to "get" these regulations, comply, and, understand them completely if you want to stay in business. no offense taken MGL as I have read them cover to cover. it is just that what is written, what is approved, and what is interpreted leave a lot of room for ambiguity. Which are the points I am trying to understand. TTB labeling person on phone tells me all it has to do is touch oak, well that aint what the BAM says right? These are the points I am trying to raise and get clarity Link to comment Share on other sites More sharing options...
Silk City Distillers Posted February 8, 2018 Share Posted February 8, 2018 I’d ask for that interpretation in writing, the phone call sounds even more ambiguous than the regulation. To me, interpreting the situation, “touching oak” means going in a barrel. Link to comment Share on other sites More sharing options...
Georgeous Posted February 8, 2018 Author Share Posted February 8, 2018 so those who use staves only in a blending tank, what can you call it? According to this thread it aint whisky? But many sell that as whiskey that I have seen. Link to comment Share on other sites More sharing options...
indyspirits Posted February 8, 2018 Share Posted February 8, 2018 25 minutes ago, Silk City Distillers said: To me, interpreting the situation, “touching oak” means going in a barrel. I dont have the BAM in front of me but I dont believe it ever mentions "barrel", but rather "container". Could that be an exploited loophole?? Link to comment Share on other sites More sharing options...
Silk City Distillers Posted February 9, 2018 Share Posted February 9, 2018 I understand this being an issue when barrels were scarce and hard to source because nobody had additional capacity, and it was nearly impossible to get a call back from a barrel manufacturer. You can pretty much get barrels from anyone in a week time. Not following why this is still a problem to be solved? Link to comment Share on other sites More sharing options...
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