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):

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?