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whiskies that fail to list State of Distillation?


wadewood
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Who's next? I'm thinking perhaps someone in Texas.

Looks like first up is 1835. Good choice, Chuck. I tried to find something that would indicate the biggest Texas violator in terms of sales or whatnot but that info is hard to find with private companies. 1835 might be it, though.

http://chuckcowdery.blogspot.com/2014/09/deep-in-heart-of-not-texas.html

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I asked a couple of Texans, who pointed me to 1835. It's pretty easy to figure out. As much of it as they're selling, at $20 to $27 a bottle, it has to be NDP, which means it was not distilled in Texas.

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sku tweeted a link today to a newspapaer article about a class action suit against Templeton.

It begins.

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Right after 5.36(d) comes 5.36(e) which says:

Country of origin. On labels of imported distilled spirits there shall be stated the country of origin in substantially the following form “Product of ______”, the blank to be filled in with the name of the country of origin.

I believe Whistle Pig is currently in violation of 5.36(e). Their earlier bottlings had the "Product of Canada" line on the back of the bottle, but none of the more recent ones do.

I know Masterson's is in compliance with 5.36(e), but I haven't had the chance to look over a bottle of Jefferson's 10 year Rye.

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  • 2 weeks later...

My favorite quote in and from the article, uttered by Double Diamond's (aka Breckenridge's) Bryan Nolt: "Talking to our peers in the industry, there are a lot of folks freaking out about label details," Nolt said. "We are pretty sure we are compliant with TTB guidelines, but like everyone else, we're making sure everything is compliant."

Gee. I'm pretty sure I'm in compliance with speed limit details because, talking to my peers, we all agree the posted limit is just a guideline. Lawyers? They're just worry warts who like to say "no".

EDIT - I forgot. I AM a lawyer. Well, I wasn't under oath when I wrote that. So, sue me.

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  • 4 weeks later...

Correct me if I'm wrong, but it looks like Angel's Envy Rye is noncompliant.

Release #1 was "CRAFTED BY HAND AND DISTILLED IN KENTUCKY" (COLA).

Release #2 was "HAND CRAFTED AND BOTTLED BY LOUISVILLE SPIRITS GROUP, BARDSTOWN, KENTUCKY" (COLA).

Given that this is 95% rye from MGPI, it looks like they've gotten the label wrong twice now.

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Officially, AE Rye isn't a rye whiskey, it's a distilled spirit specialty, as is regular Angel's Envy. Since it's not technically whiskey, it doesn't have to list state of distillation.

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Officially, AE Rye isn't a rye whiskey, it's a distilled spirit specialty, as is regular Angel's Envy. Since it's not technically whiskey, it doesn't have to list state of distillation.
Sorry for the slight thread hijack, but I was under the impression that the TTB officially designates categories for spirits. Either way, do you know why this happens to be considered a distilled spirit specialty when other finished bourbons and ryes end up being categorized under one of the other myriad TTB categories?
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AE Rye release #1 says distilled in KY and that was a total mistake. I talked to Wes Henderson about it and it was something that just slipped through; water under the bridge now. We all know where 95% Rye comes from.

As far as if something is a DSS (distilled spirits specialty) or a whiskey and requires the state to be listed, I think the difference lies in the fact that DSS are formulated products (and require a formula to be submitted).

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Officially, AE Rye isn't a rye whiskey, it's a distilled spirit specialty, as is regular Angel's Envy. Since it's not technically whiskey, it doesn't have to list state of distillation.

Thank you Chuck, I stand corrected.

I did not notice the classification, which I assumed was whiskey given the "RYE WHISKEY FINISHED IN CARIBBEAN RUM CASKS" text on the bottle. Is there any subtlety in the labeling that I missed that could indicate classification as DSS, rather than whiskey?

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Distilled Spirits Specialty (DSS) is on the COLA but not on the label. It is TTB's great catchall. "Rye Whiskey Finished in Caribbean Rum Casks" is a DSS. Is this a case where labeling consistent with the rules increases the confusion? Yes, it is.

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https://www.ttbonline.gov/colasonline/viewColaDetails.do?action=publicFormDisplay&ttbid=14219001000092

Here is a new one for Hirsch Selected Straight Bourbon Whiskey. This likely fails 5.36 (d) as I don't think it was distilled in Ohio. But there is another obvious mistake, who can spot it?

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https://www.ttbonline.gov/colasonline/viewColaDetails.do?action=publicFormDisplay&ttbid=14219001000092

Here is a new one for Hirsch Selected Straight Bourbon Whiskey. This likely fails 5.36 (d) as I don't think it was distilled in Ohio. But there is another obvious mistake, who can spot it?

I like the "Inspired by the quality of A.H. Hirsch" on the front label. :lol:

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the age statement is not in a permitted format.
Bingo. They state whiskey is between 4 and 6 years old. You can only state the age of the youngest whiskey.
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Bingo. They state whiskey is between 4 and 6 years old. You can only state the age of the youngest whiskey.

Didn't the WT Diamond do the same thing?

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Didn't the WT Diamond do the same thing?

Diamond is a bit different. It says it is a "very rare" blend of 13 to 16yo hand selected barrels. I think saying it is a blend gets them off the hook.

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Diamond is a bit different. It says it is a "very rare" blend of 13 to 16yo hand selected barrels. I think saying it is a blend gets them off the hook.
No, it doesn't. I had not noticed this before by just checked the label and find Wild Turkey guilty.
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