Question about age statements on non-straight bourbon

[GrPeMi]

I've got a question about age statements that I can't seem to figure out from my own Googling, so I hope someone here can help me out.

It is my understanding that a "straight bourbon" must be at least 2 years old, and must have a specific age statement if it is less than 4 years old.

What are the age statement requirements for bourbons that are not designated "straight bourbon"? There's a beer-barrel finished bourbon I'm looking at that only says that the bourbon is aged for "several years", and the label designation is "bourbon whiskey finished in oak beer barrels". Is there an age beyond which a non-straight bourbon is no longer required to carry an age statement?

I hope my question makes sense, and I appreciate any info...

[Josh]

I think the rules are the same, but it doesn't apply to finished products that are labeled "bourbon whiskey finished with X."

[wadewood]

Straight Bourbon is 2 years, but must have age statement under 4 years. To be called Bourbon requires aging time of 1 second; dumping into new barrel and can be dumped immediately out.

Read topic S11 here - http://www.ttb.gov/spirits/faq.shtml

Basically for a whiskey under 4 years it needs a true age statement. Also if you imply an age statement like saying 'several years' then you must actually state the age.

That all sounds cut & dried right? The issue is bourbons finished in secondary barrels are often not classified as true whiskies by the TTB. They fall under a class type 641 and are considered DSS - Distilled Spirits Specialties. Age statement requirements on DSS are murky.

[cowdery]

It's possible age statements are prohibited on 641s, as they are on blends. Any 'whiskey' that contains any neutral spirit is prohibited from bearing an age statement, that applies to blends but the 'flavored whiskeys' that contain a liqueur, such as Jack Daniel's Honey, probably contain neutral spirit, so no age statement is allowed.

On the overall question of age statements, the TTB issued some recent guidance and effectively admitted it has been steering people the wrong way on the requirement that any whiskey (excluding blended whiskey and maybe 641s) less than four years old must carry a true age statement. More about that is here.

[GrPeMi]

Ultimately, I didn't get to taste the bourbon in question tonight at the tasting event. And the distiller was only repped by the distributor, who didn't have a whole lot of facts on hand on something else that I tasted...

I just double-checked the label on the TTB site. It is a 641, so I guess age doesn't matter. I could have sworn I saw it as a bourbon the last time I looked it up. I guess my memory stinks.

I also haven't heard back from the distillery as to whether it's their own bourbon, or whether it's sourced. And info I can find out on the 'net is conflicting.

Anyway, I'd like to thank everyone for the answers...I'll have to keep in mind the wild, wild west of 641's when I'm looking at stuff.