whiskies that fail to list State of Distillation?

[sailor22]

Just wanted to post my heartfelt thanks to all of you guys who can read the regs without your eyes glazing over that are pushing this issue. Your interest and thoughtful commentary are VERY much appreciated.

Go get em guys!

[squire]

I could argue it either way (depending on who signs the check) but for me personally the burning issue is . . . why additives?

High quality, well crafted whisky doesn't need additives though I can see why bland ordinary stuff might be improved by them. The Canadians have made a science out of producing coca-cola consistent whisky by blending and using additives. Additives in beer are as old as beer itself. For ordinary, every day use stuff I can see where the average consumer just wants something consistent and cheap.

So I don't care what they toss in the $8.99 a liter special, prune wine, wood chips or eye of newt so long as all ingredients are listed on the back label. Perhaps the FDA should step in.

[cowdery]

Not to play Prove Chuck Wrong, but the TTB BAM sez that you can add flavorings to Rye Whiskey but not Straight Rye.

http://www.ttb.gov/spirits/bam/chapter7.pdf

So no flavoring in the straight whiskey class types (bourbon, rye, corn, etc) or in the bourbon (not straight) class type.

Well played, but no cigar.

I rarely consult those charts because although they are provided by TTB as an aid, they are not actually the regs and you're only in compliance if you're in compliance with the regs themselves. The charts are often wrong, as they are in this case. If you simply look at the definition of 'rye whisky' and the definition of 'straight rye whisky' you will see that the only legal difference between rye whisky and straight rye whisky is this: "(iii) Whiskies conforming to the standards prescribed in paragraphs ((1)(i) and (ii) of this section, which have been stored in the type of oak containers prescribed, for a period of 2 years or more shall be further designated as 'straight;'"

The first mention of flavoring and coloring in that section comes when we get to blends.

Edited September 6, 2014 by cowdery

[cowdery]

This issue has really caught some fire since the whole Templeton thing broke, which I wrote about here. Then I outed Tin Cup, then Widow Jane. The Widow Jane people are particularly unhappy with me.

I'm also on the record as saying that if people would just stop lying so much, I'd be happy to write about something else.

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

[ohiobourbon]

Hmm. I would like that. Meaning, that

the only legal difference between rye whisky and straight rye whisky is this ... stored in the type of oak containers prescribed, for a period of 2 years or more shall be further designated as 'straight;'"

.

I am going to get some coffee and read the regs again ...

[callmeox]

Hmm. I would like that. Meaning, that

I am going to get some coffee and read the regs again ...

Distillers...living a crazy life on the edge! [emoji2]

[ohiobourbon]

Reading on, enjoying my life-on-the-edge, here is what I see that indicates "straight whiskey" is further separated from non-straight whiskey by more than just the 2-year age requirement. Specifically, I read it that caramel can be added to whiskey (blended or not), but not to straight whiskey.

This section permits “Harmless coloring, flavoring, and blending materials” for any whiskey:

§5.23 (a)(2) There may be added to any class or type of distilled spirits,

§5.23 (a)(2)(ii) harmless coloring, flavoring, or blending materials such as caramel … if such coloring, flavoring, or blending materials do not total more than 2¹⁄₂ percent by volume of the finished product.

And then this section excludes “Harmless coloring, flavoring, and blending materials” from Straight Whiskey:

§5.23 (a) (3) “Harmless coloring, flavoring, and blending materials” shall not include (iii) any material whatsoever in the case of neutral spirits or straight whiskey …

And this section means that caramel does not need to be on the label (for whiskey that is not designated as straight):

§5.39((3) If no coloring material other than caramel has been added … no such statement is required for the use of caramel in brandy, rum, or tequila, or in any type of whisky other than straight whisky.

But I would prefer to be wrong on this ….

[dcbt]

Plenty to choose from down here, that's for sure.

[dcbt]

This issue has really caught some fire since the whole Templeton thing broke, which I wrote about here. Then I outed Tin Cup, then Widow Jane. The Widow Jane people are particularly unhappy with me.

What was Widow Jane's reply, did they respond to you privately? Did they defend themselves, deny it, etc? The different responses from the distilleries are fascinating.

[PaulO]

Stores around here have cases and cases of Tin Cup. They're even advertising it in the newspaper. No thanks. :bs:

[amg]

Stores around here have cases and cases of Tin Cup. They're even advertising it in the newspaper. No thanks. :bs:

Well, you are supporting the Indiana economy, after all...

[TunnelTiger]

What is really surprising is that the main street distillers aren't complaining to the government about it. I know they are enjoying a boom but they are losing a lot of shelf space to all of these "craft" bottles.

What they be doing is protecting their product so the general public does not turn against all bourbon/rye because of inferior product.

what is

[squire]

Also keeping a low profile while letting 'crafts' push up the prices.

[TunnelTiger]

Also keeping a low profile while letting 'crafts' push up the prices.

Squire you are most likely dead on with this point.

[mosugoji64]

I hope the liquid can speak for itself and the packaging doesn’t stand in the way of you enjoying what we believe is a great mountain whiskey.

There are no mountains in Indiana.

[squire]

Ah but what mountains of dreams flow from those plains.

[cowdery]

Reading on, enjoying my life-on-the-edge, here is what I see that indicates "straight whiskey" is further separated from non-straight whiskey by more than just the 2-year age requirement. Specifically, I read it that caramel can be added to whiskey (blended or not), but not to straight whiskey.

This section permits “Harmless coloring, flavoring, and blending materials†for any whiskey:

§5.23 (a)(2) There may be added to any class or type of distilled spirits,

§5.23 (a)(2)(ii) harmless coloring, flavoring, or blending materials such as caramel … if such coloring, flavoring, or blending materials do not total more than 2¹⁄₂ percent by volume of the finished product.

And then this section excludes “Harmless coloring, flavoring, and blending materials†from Straight Whiskey:

§5.23 (a) (3) “Harmless coloring, flavoring, and blending materials†shall not include (iii) any material whatsoever in the case of neutral spirits or straight whiskey …

And this section means that caramel does not need to be on the label (for whiskey that is not designated as straight):

§5.39((3) If no coloring material other than caramel has been added … no such statement is required for the use of caramel in brandy, rum, or tequila, or in any type of whisky other than straight whisky.

But I would prefer to be wrong on this ….

[cowdery]

What is really surprising is that the main street distillers aren't complaining to the government about it. I know they are enjoying a boom but they are losing a lot of shelf space to all of these "craft" bottles.

What they be doing is protecting their product so the general public does not turn against all bourbon/rye because of inferior product.

what is

[cowdery]

Re Widow Jane, I've exchanged a couple of emails with an underling, not the owner. Defensive, like a kid caught with his hand in the cookie jar who still insists he's being treated unfairly. Since they've always admitted to anyone who asked that the product is sourced, they feel they've been transparent. They also insist that I'm the only person in the world who knows about 5.36(d) and they blame TTB for approving a label that doesn't carry the required information. They don't seem to get that, as licensees, it is their responsibility to learn, understand, and follow the rules as written. That's their job as license holders, not TTB's.

They were coy about where it's produced but they told me the mash bill (75% corn, 21% rye, 4% malt) and noted that only one distillery uses that mash bill, but they can't actually reveal the source because they have a non-disclosure contract. Since that mash bill points to MGP, I pointed out that MGP never requires non-disclosure agreements.

They're still processing that information.

[bad_scientist]

They're still processing that information.

Chuck, you're just the best.

[amg]

Some of the big stores here in Indy are actually promoting the fact that TinCup is distilled in Indiana as a selling point.

[squire]

Makes sense, there's a growing recognition for that famous Indiana whisky.

[mbroo5880i]

Yeah, some of the more knowledgeable bourbon folks can walk you down the bourbon/rye aisle and point out all of the MGPI products. At some stores, MGPI products can account for 1/3 of the products on the shelf. Beam and HH easily consume more space.

[IowaJeff]

Templeton must be in damage control mode. Suddenly there have been a ton of TR radio ads playing in Des Moines. True to form, they have apparently learned nothing as the ads further perpetuate the fiction that TR follows an old recipe. Ultimately sales volume will tell the story, but I think the DSM Register article really hurt the TR brand here in central Iowa.

[cowdery]

Apparently the industry as a whole is more concerned about TTB fails than we ever imagined. Yesterday, a coalition of virtually all of the trade associations for the beer, wine, and spirits industries, representing all three tiers of the three tier system, sent a letter to the relevant Congressional leaders urging passage of the full amount -- $101 million -- the administration is asking for TTB funding. It notes that TTB has actually cut 50 full time staff, even though label approvals have increased by 53%.

More details are here.