Templeton Labeling, or Another TTB failure

[Brisko]

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

I missed that post, thanks for the link. As to whether TR ever listed Indiana on the label, it doesn't appear so from the COLAs that are available. I've only just recently seen a bottle in the wild, as I said.

[MrAtomic]

A question for the legally-trained among us: do any of you know the potential penalties imposed upon a company for violation of the TTB rules? I'm curious if there's any meaningful disincentive against rule-breaking, or if there's no punishment beyond having to modify an offending label. From reading Brisko's thread, and Chuck and Sku's interesting posts about the TTB, I get the feeling that companies aren't terribly concerned about repercussions.

[cowdery]

Mostly they would just be required to change the offending item. If they refused or were flagrantly flouting the rules, the TTB could force them to be pulled from the market.

I don't want to get into a lot of legalese here, but accurate rule-reading does take some legal training. It should be plain English but it's often not and there are terms-of-art involved. TTB is stretched pretty thin right now and for the most part relies on voluntary compliance. The major producers watch each other like hawks and are quick to complain if they see something wrong. The micro-producer world is still very collegial and nobody wants to be a rat. That will change.

It appears that state of distillation is required if different from the state shown for the producer on the label. TTB, however, wouldn't investigate this. They would expect the label holder to know the rules and comply. If you want to rat Templeton out to the TTB, by all means be my guest. Just be sure to give them the TTB ID number of the approved COLA you think is wrong. If you have some documentation from Templeton stating that the whiskey is distilled in Indiana, include that too.

[Leopold]

The micro-producer world is still very collegial and nobody wants to be a rat. That will change.

Astute comment yet again, Mr. Cowdery.

[MrAtomic]

Mostly they would just be required to change the offending item. If they refused or were flagrantly flouting the rules, the TTB could force them to be pulled from the market.

If you want to rat Templeton out to the TTB, by all means be my guest. Just be sure to give them the TTB ID number of the approved COLA you think is wrong. If you have some documentation from Templeton stating that the whiskey is distilled in Indiana, include that too.

Chuck,

Thanks for explaining the potential penalties. However, I'm not personally interested in finking on Templeton (I spend too much time dealing with bureaucracies already). It's also interesting to learn that the major producers essentially keep each other in line and ensure that everyone adheres to the TTB rules. And no doubt you're right that a similar situation will emerge among the micros.

[sku]

I would love to see them start enforcing the rule more aggressively. (They could at least ask on the forms what the state of distillation is and make the companies make a definitive statement.) It's one of the few tools we have as consumers to figure out where the whiskey was distilled.

Paul, even if you were to report someone, I'd be surprised if you got a response unless you had personal knowledge of some sort. Chuck get's responses from the TTB, but he's Chuck and the rest of us aren't.

[Brisko]

Is it possible that Templeton is unaware of the regulation? They have at least one youtube video that is quite open about their "partnership" with then-LDI. I can't link it easily from my tablet but it's the one with "Lifecycle Project" in the title. It's not so much that I want to rat on them as I want to know that I can trust that labels, not just theirs, are accurate.

I get that the TTB doesn't have the resources to actively police these things, and I can grasp how easily the industry could self-regulate prior to the craft movement.

Here's a question, totally unrelated to TR: what if a producer welched on an age statement? How would it be caught? I'm not thinking so much of 6 year old juice in an 8 year old label (though that's one scenario) but rather maybe 3 year old stock in an NAS? Do the produces have to maintain records to prove such things?

[wadewood]

OK Cowdery, I took your advice and wrote Thomas Hogue a very polite email asking about the distilled in state requirement.

[sku]

Here's a question, totally unrelated to TR: what if a producer welched on an age statement? How would it be caught? I'm not thinking so much of 6 year old juice in an 8 year old label (though that's one scenario) but rather maybe 3 year old stock in an NAS? Do the produces have to maintain records to prove such things?

That seems to be happening too. There are a number of craft whiskeys with no age statement that I'm betting aren't four years old. It's the same answer. It doesn't get caught.

[Leopold]

Age statement is only required for Straight Whiskey.