Diageo confirms that its new Bulleit 95 Rye is LDI. The LDI high-rye bourbon mash bill is the same as the one Four Roses makes, which is no surprise since both plants used to be owned by Seagrams.
That bourbon recipe happens to be the Bulleit Bourbon recipe. Is Diageo taking spirit distilled in Indiana, aging it in Kentucky (at Stitzel-Weller), mixing it with the all-Kentucky bourbon from Four Roses, and calling the whole thing “Kentucky Straight Bourbon Whiskey”?
The rules say producers may not misrepresent where a product was manufactured, but they don’t define ‘manufactured.’ They do say that when distilled spirits are bottled by or for a rectifier, the phrase ‘manufactured by’ may be used in lieu of the phrase ‘bottled by.’
If mere bottling is considered ‘manufacturing’ then surely aging is too.
Beyond the TTB’s general misrepresentation rule above, no entity regulates the use of ‘Kentucky’ in the phrase ‘Kentucky Straight Bourbon Whiskey.’ Nowhere is it decreed that whiskeys using the phrase must be distilled and aged in Kentucky.
So I’m not saying Diageo has done anything wrong if they are doing this, but it sure would be interesting to know.
I've asked Diageo about this point blank. They have yet to reply.