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Thread: TTB Failure

  1. #11
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    Re: TTB Failure

    I also support asking Uncle Sam for a refund (or certainly a reduction of taxes on liquor) if they aren't going to do their jobs. I'd prefer that than they just get rid of the labeling laws (since I DO want to know the age, and make sure they don't pass off 80% NGS with a "hint of whiskey" as bourbon). I mean, I know the volume of labels they are getting has increased, but gee whiz - a college intern could work the process without too much trouble.

    So what is the penalty if the laws aren't followed, or is this one of those "Well, since TTB accepted their label request, they can only ask that they correct future batches - no actual penalty/fine to the submitter"?
    Gary
    =-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=
    "Too much of anything is bad, but too much of good whiskey is barely enough." - Mark Twain
    "Because Whiskey Matters!" - David Perkins

  2. #12
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    Re: TTB Failure

    I'm still poking - here's what I found so far.

    As jburl posted above, this may be a blogger getting imprecise info re: age. OR, it could be a producer not quite complying with current label req'ts. OR, there may be some other innocent explanation. OR, not so innocent.

    A perusal of the ttb.gov website has turned up some interesting info (close to 100 pgs of law & guidance so far). It seems that ttb conducts annual audits of beer, wine, and spirits to ensure, among other things, that labels and contents match. They cannot check every producer every year but, based on the audit reports posted on the website, they do look at 300 or more per year. Check out "Labeling Resources" and "Labeling Fact Review Methods" for more info including the audit reports and info on how audits are conducted and about reviews of required reports and chem lab testing of stuff in bottles.

    ALSO, the website lists the penalties for noncompliance which mislabeling would be. (For example, see 26 USC 5602 for tax fraud and 5687 for miscellaneous noncompliance.) Penalties range from $1000 & up to 1 yr in jail to $10,000 per & 5yrs. Additional tax penalties an late payment fees would apply, too, in some cases. There may be more - I picked those as typical. I also did NOT check the federal criminal code to see what other crimes might arise (false statement on federal form, etc.).

    I'm not done poking (since I'm learning a lot) but since I found info that addresses some of the concerns raised above, I thought I'd share what I found so far.

  3. #13
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    Re: TTB Failure

    Thanx for doing the 'poking', Harry. Interesting and informative stuff.

  4. #14
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    Re: TTB Failure

    I second that. Thanks Harry!!

  5. #15
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    Re: TTB Failure

    Third! The motion carries! Thanks Harry!
    Gary
    =-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=
    "Too much of anything is bad, but too much of good whiskey is barely enough." - Mark Twain
    "Because Whiskey Matters!" - David Perkins

  6. #16
    Bourbonian Of The Year 2013 and Guru
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    Re: TTB Failure

    Came across this article in an industry trade, today. Not entirely germane to this discussion exactly, but it had enough things in it that were at least in the ballpark, that maybe it exposes a trailhead or two to our researchers...

    http://www.packagingdigest.com/regul...s?cid=nl.pkg04
    JOE

    Wag more.
    Bark less.

    "Every bottle is its own learning experience." -- Sensei Ox-sama

  7. #17
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    Re: TTB Failure

    Yeah, I don't have the time to do the "poking" myself, but it's an interesting situation and I appreciate the info obtained thus far.

  8. #18
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    Re: TTB Failure

    Greetings. I have attached a pdf document (mainly because I couldn't figure out how to cut&paste a WORDor plain text doc into a "Go advanced/Reply to thread" post. It contains what I found (or didn't find) re: WA's 3 yr old SB without an age statement on the bottle. Maybe the doc's too long. Whatever, I didn't want to retype it because I always have trouble with the SB editor - delete key sometimes doesn't work, ltters don't appear ometimes, etc.

    SO, if one of the moderators wants to PM me on how to do a C&P, I'll do it. OR, if one wants to just C&P for me, go ahead.

    [EDIT - Added the following sentences after I made sure the attachment worked: The bottom line is: Section 5.40 of Title 27 o f the Code of Federal Regulations explicitly requires a statement of age on the label of a straight bourbon whisky that is less than 4 years old. The TTB website has multiple resources restating this requirement. I could find nothing on the TTB website indicating that the TTB had ever affirmatively authorized an exception to this requirement.]

    Happy reading.
    Attached Files Attached Files
    Last edited by Harry in WashDC; 03-03-2014 at 20:36.

  9. #19
    Mr. Anal Retentive Bourbon Drinker
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    Re: TTB Failure

    If we thought a 3 year old labeled as Straight Bourbon with NAS was bad, how about a 70 proof root beer flavored whiskey listed as Bottled in Bond? (Steve Ury found this one) - https://www.ttbonline.gov/colasonlin...14006001000453

  10. #20
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    Re: TTB Failure

    Quote Originally Posted by wadewood View Post
    If we thought a 3 year old labeled as Straight Bourbon with NAS was bad, how about a 70 proof root beer flavored whiskey listed as Bottled in Bond? (Steve Ury found this one) - https://www.ttbonline.gov/colasonlin...14006001000453
    WhatWhat? I have an excuse to go learn more about BIB req'ts and flavored whisky rules? Boy, howdy, what great day this will be - snowed in with just my PC and a handle of BT at my side. And no baseball to distract me.

 

 

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