Templeton Labeling, or Another TTB failure
Now that Templeton is ubiquitous in the Twin Cities market, I actually had the chance to look at the label.
As I suspected, it read, "Produced and Bottled By: Templeton Rye Spirits, LLC, Templeton, Iowa." A cursory COLA search confirms that they've always labeled it this way*.
However, according to the federal regs, Title 27, section 5.36(d):
Quote:
State of distillation. Except in the case of “light whisky”, “blended light whisky”, “blended whisky”, “a blend of straight whiskies”, or “spirit whisky”, the State of distillation shall be shown on the label of any whisky produced in the United States if the whisky is not distilled in the State given in the address on the brand label. The appropriate TTB officer may, however, require the State of distillation to be shown on the label or he may permit such other labeling as may be necessary to negate any misleading or deceptive impression which might be created as to the actual State of distillation. In the case of “light whisky”, as defined in § 5.22(b)(3), the State of distillation shall not appear in any manner on any label, when the appropriate TTB officer finds such State is associated by consumers with an American type whisky, except as a part of a name and address as set forth in paragraph (a) of this section
(emphasis mine)
It's my understanding that their rye is from the old Seagrams plant so it seems really clear to me that their labeling is deceptive and in conflict with the federal regulations. If the TTB isn't going to enforce their own regs, who is?
*At the risk of threadjacking my own thread, it's quite interesting to look at Templeton's COLA history. Their first was for a "Single Barrel Blended Rye," a real head scratcher in it's own right, but the really interesting ones are the "Kerkhoff" recipe and the Quasquicentennial. The Kerkhoff was "spirits distilled from cane (90%) and rye (10%)," and the tonguetwister was similar except that it was 75% cane, 20% grain, and 5% rye. Now, who knows if these ever got made-- gotta wonder, if they were sold, who actually made it?
Re: Templeton Labeling, or Another TTB failure
Quote:
Originally Posted by
Brisko
If the TTB isn't going to enforce their own regs, who is?
Unfortunately the answer is nobody. You can try to get the TTB to do their job by filing a complaint. I have filed a complaint using this exact 5.36(d) code requirement and their standard reply is "We will look into the situation and appropriate action will be taken, if necessary".
Re: Templeton Labeling, or Another TTB failure
Quote:
Originally Posted by
wadewood
Unfortunately the answer is nobody. You can try to get the TTB to do their job by filing a complaint. I have filed a complaint using this exact 5.36(d) code requirement and their standard reply is "We will look into the situation and appropriate action will be taken, if necessary".
Their policy is they don't talk about the specifics of label issues except with the label holder. You can, however, ask them to clarify the meaning of a rule, in the context of a specific, and while they won't reply with reference to the specific, they in some cases will reply in a general way that allows you to read between the lines. Thomas Hogue is their public affairs liason.
It helps to be nice.
Re: Templeton Labeling, or Another TTB failure
Brisko, right section (5.36), wrong part. You're in 5.36(d), which is "state of distillation," and not implicated here. You want 5.36(a)(4) and 5.36(a)(6).
The gist of it is, the rules treat "produced by" and "bottled by" as synonyms, so aside from being redundant, "produced and bottled by" is acceptable when the only production being referred to is mere bottling. You may think 'produced' should mean 'distilled,' but TTB doesn't see it that way.
Re: Templeton Labeling, or Another TTB failure
Quote:
Originally Posted by
cowdery
Brisko, right section (5.36), wrong part. You're in 5.36(d), which is "state of distillation," and not implicated here. You want 5.36(a)(4) and 5.36(a)(6).
The gist of it is, the rules treat "produced by" and "bottled by" as synonyms, so aside from being redundant, "produced and bottled by" is acceptable when the only production being referred to is mere bottling. You may think 'produced' should mean 'distilled,' but TTB doesn't see it that way.
Are you sure? If you read the part I bolded it sounds like they are saying the state of distillation is required to be listed if it is different from the main brand label address. Maybe I am reading it wrong.
I understand that "produced" may be accuratee, especially since they (supposedly) age it in IA.
For the sake of comparison, the various young Willett ryes state "Distilled in Indiana bottled in Bardstown, Kentucky." I assue that KBD is following the rule (by my reading) while Templeton is not.
Re: Templeton Labeling, or Another TTB failure
While its nice to have the rules, when they get to be used in what appears to be a too flexible way, their use is greatly diminished. Hell, besides most of the folks here, who out in the rest of the world knows such things exist?
Besides, I have my own rule, I just don't buy Templeton. Its a simple rule. Pretty easy to follow.
It's a decent product, but it is not worth the money that they are asking for it.
B
Re: Templeton Labeling, or Another TTB failure
Quote:
Originally Posted by
BFerguson
While its nice to have the rules, when they get to be used in what appears to be a too flexible way, their use is greatly diminished. Hell, besides most of the folks here, who out in the rest of the world knows such things exist?
Besides, I have my own rule, I just don't buy Templeton. Its a simple rule. Pretty easy to follow.
It's a decent product, but it is not worth the money that they are asking for it.
B
It has been said before; we are the .001%. :grin:
And your rule is also my rule.
Re: Templeton Labeling, or Another TTB failure
subsection (d) does appear to require the accurate state of distillation, but I'm not too versed on these regs or how they are interpreted and applied.
I know that Templeton was initially a single barrel and switched to 'small batch.' I don't what the heck a single barrel blended whiskey is though.
I too have stopped buying it (I think I've only had two bottles, so not sure I even started). It's a perfectly good product, but now that rye has become so popular there are plenty of cheaper options of an equal or higher quality, even in Iowa. I have started seeing it around more. For a long time everyone in Iowa was crazy for it and it was never on the shelves. That's surely part increased production, or sourcing, but may also be that some of those TR crazy people picked up a bottle of Bulleit or some other rye and found it a cheaper substitute.
Re: Templeton Labeling, or Another TTB failure
On the concept of a single barrel blended rye, I don't know (of course) what will actually be in the bottle if this is ever released. However, I don't think the term is a contradiction in terms. Blended rye whiskey is a mixture of straight rye and GNS or any whiskey where the straight rye is at least 51% of the mix on a proof gallon basis (see section 5.22(a)(4), SOI). Say you barelled 2 year old straight rye with a 1 year old rye whiskey where the straight was 51% of the mix on a proof gallon basis. And then you aged it 2 years. If you filled bottles from that one barrel, that would seem to me a single barrel blended rye.
Gary
Re: Templeton Labeling, or Another TTB failure
There is indeed a state of distillation requirement and it is not being enforced. I wrote about the issue a few months back, linked below. I had thought Templeton used to say "produced in Indiana" on the label, but I could be wrong.
http://recenteats.blogspot.com/2012/...-state-of.html
