Jack Rye?

[cowdery]

"Probabably" is a way to indicate high probability. Or is that high probabability?

[Gillman]

If you are talking about me, none of my theories are "silly". They are attempts to parse a label in the context of statements I heard in an interview with Jeff Arnett, Mark's last statements in the thread, and also taste reports which seem to veer away from a typical neutral spirits palate. Rye is not the only "grain" in rye mash, so that doesn't necessarily satisfy a statement of grain type as you've pointed out yourself.

I noticed right away the reference to neutral spirit on the label and have been trying to figure out ever since what it means.

On the other hand, it may be and I have said I incline currently to thinking, it is 100% neutral spirit.

But until there is final clarification, other possibilities still exist. Amongst these, the most plausible is that it is new make rye mash spirit. I can't explain why the term neutral spirit is on the label if this is the case, maybe it is an "error", or the government allowed it for some specific reason. I don't know.

One of the whiskey writers will nail it down soon and tell us, I'm sure.

Gary

Edited October 8, 2012 by Gillman

[wadewood]

The approved TTB label says neutral spirit aka Jack Daniel's Vodka. Despite any comment Jeff Arnett made to the contrary, the regs are well stated - this product is vodka.

Gary -Canada does have different regs than the US, so perhaps Jeff could make his statements addressing Canada or some other market, but in the US it simple can't be spun any other way.

[oknazevad]

The COLA also shows a type of Neutral Spirits, so either the TTB has gone further off the rails or the fibbing is strong on this product from BF.

Also in the TTB registry for JD are label approvals for whiskey products called Before and After in 375ML sizes. Keep an eye out for a white whiskey/aged whiskey twin pack from the house of Daniel's.

Edited October 8, 2012 by oknazevad

[wadewood]

I've been posting on Whiskycast facebook site, I think this is the direct link - https://www.facebook.com/photo.php?fbid=10151056494822116&set=a.124106887115.115731.46314247115&type=1&theater

Mark's says Jack received TTB approval to call this spirit distilled to 140 proof a neutral spirit. There is no TTB class/type setup for an unaged Rye Whiskey.

I say that the TTB screwed up (and not for the 1st time). The regs clearly state neutral spirits are to be distilled over 190 proof. They should not have given Jack Daniels an exception for this. Not that it will do much good, but I will file a complaint on their web based application system. Instead of giving an exception to the "class", the TTB should have given an exception to the "type" I would suggest allowing the type to be "Unaged Rye Whiskey", which makes way more sense than calling this a neutral spirit.

[cowdery]

My guess with the before and after products is that they want to make them available to ambassadors who will do tastings around the country. As I mentioned previously, they've been doing that particular tasting at the distillery, for press and industry guests, for years. They probably need to formalize the packaging for that kind of distribution. I've noticed some changes in the way they label tasting samples sent to people like me.

I don't want to single out any individuals, but as Wade points out, the range of possibilities regarding the labeling issue is quite narrow, therefore any theory outside that range is, at best, 'silly' or, if you prefer, 'fanciful.'

[cowdery]

I've been posting on Whiskycast facebook site, I think this is the direct link - https://www.facebook.com/photo.php?fbid=10151056494822116&set=a.124106887115.115731.46314247115&type=1&theater

Mark's says Jack received TTB approval to call this spirit distilled to 140 proof a neutral spirit. There is no TTB class/type setup for an unaged Rye Whiskey.

I say that the TTB screwed up (and not for the 1st time). The regs clearly state neutral spirits are to be distilled over 190 proof. They should not have given Jack Daniels an exception for this. Not that it will do much good, but I will file a complaint on their web based application system. Instead of giving an exception to the "class", the TTB should have given an exception to the "type" I would suggest allowing the type to be "Unaged Rye Whiskey", which makes way more sense than calling this a neutral spirit.

Mark's just speculating too and so, for that matter, is Arnett. He's a distiller, after all, not a compliance officer.

I'm trying to get an answer but the Columbus Day holiday may be working against me.

Edited October 8, 2012 by cowdery

[Josh]

Mark's just speculating too and so, for that matter, is Arnett. He's a distiller, after all, not a compliance officer.

I'm trying to get an answer but the Columbus Day holiday may be working against me.

You and the Indians both.

[cowdery]

Here's the reply from Jack Daniel's PR agency. I'm flabbergasted, but there it is. As I replied to him, the definition of ‘neutral spirits,’ as a class designation, is distinguishable from the definition of vodka, which appears below it as a type designation within the class of neutral spirits, much as ‘rye whiskey’ appears as a type designation within the class of whiskey. The definition of ‘neutral spirits’ as a class, while it does not include the "without distinctive character, aroma, taste, or color" requirement for vodka, does clearly state that the spirit must be distilled above 190° of proof. The ruling, as you describe it, would seem to undermine the definition of neutral spirits for more purposes than just the labeling of this one Jack Daniel’s product.

I have made inquiries to TTB.

Here's his response:

Mr. Cowdery,

Good afternoon. Thank you for your inquiry. Per the portion of the Code of Federal Regulations describing neutral spirits (vodka) and whiskey copied and provided below, vodka has to be distilled at or above 190 proof and “without distinctive character, aroma, taste, or color. Whiskeys must be distilled at less than 190 proof and “possess the taste, aroma, and characteristics generally attributed to whisky, stored in oak containers (except that corn whisky need not be stored), and bottled at not less than 80 proof.”

The net of this is that our unaged rye did not satisfy the “Class 2; Whiskey” requirement of being stored in an oak container, therefore the TTB ruled that it should be labeled as a “neutral spirit” even though it was distilled at 140 proof and obviously violates the stated vodka requirement of being “without distinctive character, aroma, taste, or color.” By this ruling, it is assumed that the TTB considers all whiskies (except corn whisky) to be neutral spirits until they enter the barrel for maturation. Jack Daniel’s packaging and legal departments argued that the Tennessee Unaged Rye should be labeled as an “unaged whiskey” which we felt more accurately described the nature of the product to the consumer, but the TTB ruled against this proposal and would only approve the label under the category “neutral spirit”.

Jack Daniel’s understands this category classification can certainly be a point of confusion. The Jack Daniel’s Tennessee Unaged Rye is a fermented mash of 70 percent rye, 18 percent corn, and 12 percent malted barley that was distilled at 140 proof and charcoal mellowed, but it was never entered into an oak barrel.

Again, thank you for your inquiry. Please let me know if you have more concerns or questions.

Title 27: Alcohol, Tobacco and Firearms

PART 5—LABELING AND ADVERTISING OF DISTILLED SPIRITS

Subpart C—Standards of Identity for Distilled Spirits

§ 5.22 The standards of identity.

Standards of identity for the several classes and types of distilled spirits set forth in this section shall be as follows (see also §5.35, class and type):

(a) Class 1; neutral spirits or alcohol. “Neutral spirits” or “alcohol” are distilled spirits produced from any material at or above 190° proof, and, if bottled, bottled at not less than 80° proof.

(1) “Vodka” is neutral spirits so distilled, or so treated after distillation with charcoal or other materials, as to be without distinctive character, aroma, taste, or color.

(2) “Grain spirits” are neutral spirits distilled from a fermented mash of grain and stored in oak containers.

( Class 2; whisky. “Whisky” is an alcoholic distillate from a fermented mash of grain produced at less than 190° proof in such manner that the distillate possesses the taste, aroma, and characteristics generally attributed to whisky, stored in oak containers (except that corn whisky need not be so stored), and bottled at not less than 80° proof, and also includes mixtures of such distillates for which no specific standards of identity are prescribed.

Thanks,

Rob Hoskins

Jack Daniel’s Media Relations

[mark fleetwood]

Just sitting here waiting for a ski app to load (and becoming increasingly certain that the snow will melt in April before it does) it's frustrating to see the industry trot out these suspect (at best) line extensions that seek to capitalize on big brand names and an increasing demand in whiskey. Quick, stock up on Heaven Hill BIB, VOB100 and WSR while you can. It won't be long before Echo Spring 105% Near-Grain Thrice Distilled Normandy Hooch or Beam Family 1798 Original CornRye White Mule Spirit Whiskee debut on shelves for $79! Larcey's one great thing; but these "specialties" are distracting, and at prices that are insulting.

[wadewood]

The net of this is that our unaged rye did not satisfy the “Class 2; Whiskey†requirement of being stored in an oak container, therefore the TTB ruled that it should be labeled as a “neutral spirit†even though it was distilled at 140 proof and obviously violates the stated vodka requirement of being “without distinctive character, aroma, taste, or color.†By this ruling, it is assumed that the TTB considers all whiskies (except corn whisky) to be neutral spirits until they enter the barrel for maturation. Jack Daniel’s packaging and legal departments argued that the Tennessee Unaged Rye should be labeled as an “unaged whiskey†which we felt more accurately described the nature of the product to the consumer, but the TTB ruled against this proposal and would only approve the label under the category “neutral spiritâ€.

Heaven Hill's Trybox Rye Whiskey is labeled Rye Whiskey - Straight from the Still. It's unaged Rye Whiskey and appropriately labeled. Why would TTB approve this from Heaven Hill and not Brown Forman???

[Josh]

Dumbfounded. Who the hell is running the TTB? And what are they drinking?

[cowdery]

Heaven Hill's Trybox Rye Whiskey is labeled Rye Whiskey - Straight from the Still. It's unaged Rye Whiskey and appropriately labeled. Why would TTB approve this from Heaven Hill and not Brown Forman???

Heaven Hill did a touch-and-go with barrels, new charred barrels at that. That's what everyone has done until now. There's been a tacit understanding that brief wood contact isn't aging in any meaningful sense, pluse TTB doesn't care about pharases such as 'straight from the still.'

[cowdery]

Dumbfounded. Who the hell is running the TTB? And what are they drinking?

I hope TTB will tell us its side, because JD's story is just a little too self-serving.

[Gillman]

The outcome strikes me as no less odd than it does others, but it is something I felt was plausible, based on the taste reports and what Mark had reported. I took some ribbing, but I was right in the end, and as no one else has said so, I will.

Gary

[T Comp]

It's one of the better threads on the board in recent times. 99.999% of the people could care less but some of us do.

[Josh]

It's one of the better threads on the board in recent times. 99.999% of the people could care less but some of us do.

[Gillman]

Josh, Thad, I can just see the t-shirt.

Gary

P.S. Some irony in the number for admirers of spirituous beverages, but never mind.

[mrviognier]

We were so busy at the recent SFO WhiskeyFest that I didn't get a chance to get from behind our table all night. Saw that Jack Daniels was pouring a unaged Rye. Anyone had a chance to try it yet?

[HighInTheMtns]

http://www.straightbourbon.com/forums/showthread.php?17931-Jack-Rye

You missed all the fun, Mat!

[cowdery]

The TTB says it agrees with me, but bureau policy prevents them from telling me what they are going to do about it. I have asked Jack Daniel's for comment. Still waiting to hear back. Edited October 24, 2012 by cowdery