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  1. #1
    Bourbonian of the Year 2002 and Guru
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    Is Some Bulleit Bourbon Distilled in Indiana?

    Consider this.

    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”?

    Can they?

    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.

  2. #2
    Bourbonian of the Year 2010 and Guru
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    Re: Is Some Bulleit Bourbon Distilled in Indiana?

    27cfr5.22 (b)(1)(iii)

    ..."Straight whisky" includes mixtures of straight whiskies of the same type produced in the same State.

    27cfr5.22 (b)(5)(ii)

    "A blend of straight whiskies" consisting entirely of one of the types of straight whisky shall include straight whisky of the same type which was produced in the same State or by the same proprietor within the same State,


    I think the "same state" modifier in both of these would prevent something from LDI and FR being put in the same bottle being called straight in any way.
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  3. #3
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    Re: Is Some Bulleit Bourbon Distilled in Indiana?

    I thought that if they are calling it straight, it can't be a blend from more than one state. If it is a blend of straights from more than one state, wouldn't it have to be "a blend of straight whiskeys"?

    UPDATE: Sorry to repeat, posted this before I saw Barturtle's response.

  4. #4
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    Re: Is Some Bulleit Bourbon Distilled in Indiana?

    Quote Originally Posted by sku View Post
    I thought that if they are calling it straight, it can't be a blend from more than one state. If it is a blend of straights from more than one state, wouldn't it have to be "a blend of straight whiskeys"?

    UPDATE: Sorry to repeat, posted this before I saw Barturtle's response.
    I think that was the point "Crotchety" Cowdery was making, can aging in Kentucky be considered "manufactured" in Kentucky there by meeting the requirements. The laws do not say "distilled" and "manufactured" is not defined; I guess it depends on what the meaning of the word "IS" is

  5. #5
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    Re: Is Some Bulleit Bourbon Distilled in Indiana?

    Quote Originally Posted by MissinER101 View Post
    I think that was the point "Crotchety" Cowdery was making, can aging in Kentucky be considered "manufactured" in Kentucky there by meeting the requirements. The laws do not say "distilled" and "manufactured" is not defined; I guess it depends on what the meaning of the word "IS" is
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  6. #6
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    Re: Is Some Bulleit Bourbon Distilled in Indiana?

    Is this that much different than Va Gentlemen saying Virginia Straight Bourbon Whiskey (or the Bowman products for that matter) by A. Smith Bowman Distillery? It's made by Buffalo Trace in KY but aged in VA. It seems strikingly similar, but I guess it's not as offensive to some being VA straight bourbon as opposed to KY Straight Bourbon.

    If they can stretch where it's manufactured, can they stretch how it's manufactured? Does the ambiguity stop at location? I certainly hope it does, maybe the regulators focus on the "how" and not the "where" to ensure quality.
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  7. #7
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    Re: Is Some Bulleit Bourbon Distilled in Indiana?

    At least va gentleman is redistilled in Virginia.

  8. #8
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    Re: Is Some Bulleit Bourbon Distilled in Indiana?

    This reminds me of the discussion we had some time ago in respect to bonded bourbon. IIRC, the suggestion was made by some that a distillery to which new make was trucked and aged from another location could be mentioned on the label as the source distillery for the bond. It may be that kind of logic at work here if some Bulleit new make is made at LDI. Given that the character of bourbon derives - its essential character - from aging, if the aging all takes place in one State, it seems okay to me that it be indicated as the State of production. That's just a personal impression, I haven't looked to the standards but if that is what is happening I'd have no issue with it.

    Gary

  9. #9
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    Re: Is Some Bulleit Bourbon Distilled in Indiana?

    And you wonder why Diageo doesn't like talking to you Chuck.
    Last edited by p_elliott; 03-10-2011 at 07:17.
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  10. #10
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    Re: Is Some Bulleit Bourbon Distilled in Indiana?

    Quote Originally Posted by MissinER101 View Post
    I think that was the point "Crotchety" Cowdery was making, can aging in Kentucky be considered "manufactured" in Kentucky there by meeting the requirements. The laws do not say "distilled" and "manufactured" is not defined; I guess it depends on what the meaning of the word "IS" is
    I think "produced" is the operative term here, but that does note appear to be a defined term either, at least in that section of the regs, so it would be up to the TTB to determine what it means, but if produced simply means bottled, it would eviscerate the regs, as how do you bottle something in more than one state (maybe if you set up a plant at the four corners). However, I suppose, if it were used broadly, it could include ageing, diluting with water and any other activity that goes into making the final product.

 

 

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