Labeling Question

[jburlowski]

I was fortunate to receive as a Xmas present a bottle of rye from the George Washington distillery at Mt. Vernon. It is labeled as "straight rye whiskey". Since the distillery began (modern) operations in 2009, the whiskey is clearly less than four years old. Thus, as a straight, an age statement is required.

However, none appears on the label. The only statement of age is on the hang tag which is attached to the neck of the bottle with the typical elastic string. It states: "aged more than two years in oak barrels, to give it a mellow flavor..."

A quick reading of the regs says that the AS "Must generally appear parallel to the base of the container" and "Must appear separate and apart from any other descriptive or explanatory information".

So does this wording and particularly it's placement on the hang tag (which can easily become separated from the bottle) conform with the letter and spirit of the regs?

[B.B. Babington]

somebody likes you. the 2 yr is high $$. Virginia ABC lists two offerings, a "rye" with little age and no age statement and a "straight rye" with 2yr age statement.

Virginia ABC seems to be happy with the way it's labeled. At least so far.

And Virginia ABC is NOT happy with the way they were depicted in the moonshiners episodes and are demanding disclaimers be placed on the program. Apparently the producers misled Virginia ABC on how the show would present the material.

[Lazer]

I think it probably does violate the letter and the spirit of the law. That's the beauty of an over-sized federal gov't, they can't bother with enforcing all of their laws. How does the gov't profit from enforcing this law? Just my opinion.

[White Dog]

I think it probably does violate the letter and the spirit of the law. That's the beauty of an over-sized federal gov't, they can't bother with enforcing all of their laws. How does the gov't profit from enforcing this law? Just my opinion.

It appears that all kinds of things have been slipping by the feds lately, so this one doesn't surprise me. The current David Nicholson DSP-KY-16, for example.

Not trying to get all PRNC, but the government doesn't "profit" when it ensures that other foods meet the proper health standards.

[clingman71]

It appears that all kinds of things have been slipping by the feds lately, so this one doesn't surprise me. The current David Nicholson DSP-KY-16, for example.

Not trying to get all PRNC, but the government doesn't "profit" when it ensures that other foods meet the proper health standards.

[White Dog]

I get a little pissed every time I see those Nicholson labels.

[Josh]

The Nicholson thing is bad, no doubt. But IMO what's worse than using outdated labels is the kind of stuff John is talking about. Mislabeling something as straight, a very specific legal term, when it's not is a bald-faced lie. George's old place is not the only micro doing it either. I strongly suspect that Grand Traverse Distillery is doing the same thing, using the word straight without an age statement when the product is under 4 y/o.

[Lazer]

Not trying to get all PRNC, but the government doesn't "profit" when it ensures that other foods meet the proper health standards.

[White Dog]

What's PRNC? does that mean nanny state?

[bgageus]

My reading of the rule is that it must be 2 years old to be called "straight".

Correction:

I read the post wrong I thought it was about labeling it straight, not the posting of the age statement.

[keith18]

Just a hypothetical question: How does the government know how long something was aged? For example, if bourbon X claimed it was aged 7 years when in fact it was only aged 5 years, how would the regulators go about verifying the age statement?

I suppose people with great taste buds might be able to say, "This tastes young for 7 years," but I doubt they'd be able to put a year on it. Does TTB keep a log of what/when/where juice goes into the barrel?

[cowdery]

TTB has been letting a lot of things slip through lately, to the point where I don't even try to figure it out. The way the system works, producers submit labels for approval and if TTB says okay then it's 'legal' even if it clearly violates the regs. The problem has become so common and widespread, I just write anomalies off to TTB error.

As for the veracity of the age statements, it's pretty much an honor system but with pretty high penalties if you get caught lying. The TTB does do audits for tax purposes using data supplied by the producers which would be pretty hard to falsify, but that's mostly for tax purposes, not for labeling purposes.

[keith18]

Thanks Chuck. That's kind of what I expected, but thanks for the reply.