Definition of Craft

[StarSurfer55]

Is there a legal definition of Craft Bourbon.  I saw where Barrell bourbon was called a Craft Bourbon which I understand their craft is in blending as their product is sourced. I am not demeaning the skill to blend to a good and consistent product but to me Craft would mean that you made it as well. Thoughts?

[flahute]

 

there is a legal definition - a couple of them in fact depending on which industry organization you refer to. The definitions refer to both size of premises and not exceeding a max output (number of barrels or proof gallons) per year. I'd have to look it up again.

[Harry in WashDC]

At least two trade associations concentrate their efforts on issues of interest to "craft distillers" and to nondistiller producers of craft distilled spirits.  The major distilled spirits trade association mentions them on its website but provides no definition.

 

The American Distilling Institute (ADI), a membership organization, calls itself "The Voice of Craft Distilling".  Website is https://distilling.com

 It has its own "Craft Certification Program" for qualifying members.  It allows qualifiers to put stickers on their products stating that the products are certified as craft.  Distiller qualifiers must be independently owned, produce their own distillate, and otherwise control its handling, aging, bottling, etc., up to sale to another party (like a wholesaler or restaurant).  Annual sales must be less than 100,000 proof gallons.  See Steve's comment re: that.  For more detail on the certifications, visit the website.

 

The American Craft Spirits Association (ACSA) is member-owned also and advocates for "the community of craft spirits producers".  Website is https://americancraftspirits.org/      It has several membership categories, but voting members are limited to independent, licensed (i.e. DSP) distillers with annual sales of less than 750,000 proof gallons.  "Independent" means no producer/distiller with annual sales exceeding 750,000 proof gallons can own, directly or indirectly, 50% or more of the member.

 

The Distilled Spirits Council of the United States (DISCUS) does not have a definition/description of "craft" but does have a special membership category for such distillers/producers.  See https://www.distilledspirits.org/why-join/  for more info.

 

While listening to the rain and doing this research, such as it is, I found an undated article on vinepair.com titled, "What is craft distillery" Go to  https://vinepair.com/spirits-101/what-is-craft-distillery/      although it really did not add much.

 

The Tax Cut and Jobs Act of 2017 cut excise taxes on alcoholic beverages made by small producers/distillers, The reduction expires soon.  I could not find a section-by-section analysis of the law setting out what "small" is before I got bored.

 

 

 

[VAGentleman]

On 8/31/2020 at 12:48 PM, Harry in WashDC said:

 

 

The Tax Cut and Jobs Act of 2017 cut excise taxes on alcoholic beverages made by small producers/distillers, The reduction expires soon.  I could not find a section-by-section analysis of the law setting out what "small" is before I got bored.

 

 

 

The FET is cut to $2.70 per proof gallon for the first 100,000 proof gallons for all Distilleries big and small, though obviously focused on the small distilleries

[Harry in WashDC]

4 hours ago, VAGentleman said:

The FET is cut to $2.70 per proof gallon for the first 100,000 proof gallons for all Distilleries big and small, though obviously focused on the small distilleries

Thx.

[WhiskeyBlender]

@StarSurfer55, for better or worse, years ago I advocated for ADI to add "Craft Blended Spirit" as a category, at least to their judging competition, because I felt that the art of blending in the United States was not well understood and that the art/science of fermentation & distillation was always considered "superior."  This seemed to be the opposite of what is celebrated in the tradition that I originally come from, which is the French artisanal brandy production and blending tradition. In that tradition, having patience in one's work, taking the proper amount of time to mature products properly, and being meticulous in the details is where the "craft" lies. 

 

I'm not saying that I'm "right," but in my professional life as a blender, I see "craft" as not necessarily just about doing distillation, but about taking the time and having the patience to be meticulous in one's work, and in fact "making or doing things by hand."  So in my case, with some of the distilleries I blend for that source (and most of the ones I work with do NOT source), this would mean paying great attention not just to the blending of sourced barrels, but to their "élevage" once the barrels are in your care. Élevage literally means to raise the barrels as if they were children, to bring them from infancy to maturity during the maturation process. This might mean that if the barrels are maturing in an environment that is too damp or cool and the maturation has stalled, to put them in an environment where it is drier and warmer, or visa versa, or for products where it is legally permissible to do so, to put them into different cooperage, such as more exhausted barrels that will serve as oxidation vessels, or if they need more tannin, to move them accordingly, etc. And for some distilleries I work with, for their highest end whiskeys, I will have samples sent to me (since I can't travel during the Covid lockdown) every two weeks so that I can keep tabs on the maturation progress. This is just the tip of the iceberg to the art of being a Cellar Master/Master Blender. 

 

I don't know enough about Barrel Bourbon to know what kind of maturation and blending techniques they're employing in order to be called "Craft Bourbon," so I can't give any meaningful feedback in regard to them. That said, if you are doing maturation and blending as "craft," then it is truly more than a full time job to analyze the stock, make maturation or barreling adjustments as needed, and to be really "hands on" in the process. 

 

By the same token, there are many "craft" distilleries out there that might ferment, distill, and age their own distillate, but then they use small barrels or poor quality cooperage, and generally have a "set it and forget it" mentality when it comes to aging their stock, with no regard to maturation conditions, or to proper amounts of humidity or temperature for the products they are making, etc. Sure enough, they've fermented and distilled their own product, but perhaps they haven't taken the time and had the patience to properly clean and sanitize their fermentation tanks, so that nasty bacterial contaminations from lactobacillus or acetobacter set up, or if they use a pot still to make Bourbon, they don't know how to properly make the cuts so that when their Bourbon matures, it won't taste like an oak stick with alcohol, etc. Just because they have a pot still, they're a small distillery, and make their own distillate, does this really mean that they are "craft," in that they are meticulous in their production details, have the patience to do things properly, and to age products for a truly proper amount of time, and to insure quality, and aren't just trying to push unfinished product out the door because they didn't do their business plan right, etc.? 

 

I know all of this stuff has been addressed ad nauseam over the years, and the different philosophies of what constitutes "craft" have their proponents on every side of the fence. Just my two cents on the matter......

 

Cheers,

Nancy

 

 

[flahute]

33 minutes ago, WhiskeyBlender said:

@StarSurfer55, for better or worse, years ago I advocated for ADI to add "Craft Blended Spirit" as a category, at least to their judging competition, because I felt that the art of blending in the United States was not well understood and that the art/science of fermentation & distillation was always considered "superior."  This seemed to be the opposite of what is celebrated in the tradition that I originally come from, which is the French artisanal brandy production and blending tradition. In that tradition, having patience in one's work, taking the proper amount of time to mature products properly, and being meticulous in the details is where the "craft" lies. 

 

I'm not saying that I'm "right," but in my professional life as a blender, I see "craft" as not necessarily just about doing distillation, but about taking the time and having the patience to be meticulous in one's work, and in fact "making or doing things by hand."  So in my case, with some of the distilleries I blend for that source (and most of the ones I work with do NOT source), this would mean paying great attention not just to the blending of sourced barrels, but to their "élevage" once the barrels are in your care. Élevage literally means to raise the barrels as if they were children, to bring them from infancy to maturity during the maturation process. This might mean that if the barrels are maturing in an environment that is too damp or cool and the maturation has stalled, to put them in an environment where it is drier and warmer, or visa versa, or for products where it is legally permissible to do so, to put them into different cooperage, such as more exhausted barrels that will serve as oxidation vessels, or if they need more tannin, to move them accordingly, etc. And for some distilleries I work with, for their highest end whiskeys, I will have samples sent to me (since I can't travel during the Covid lockdown) every two weeks so that I can keep tabs on the maturation progress. This is just the tip of the iceberg to the art of being a Cellar Master/Master Blender. 

 

I don't know enough about Barrel Bourbon to know what kind of maturation and blending techniques they're employing in order to be called "Craft Bourbon," so I can't give any meaningful feedback in regard to them. That said, if you are doing maturation and blending as "craft," then it is truly more than a full time job to analyze the stock, make maturation or barreling adjustments as needed, and to be really "hands on" in the process. 

 

By the same token, there are many "craft" distilleries out there that might ferment, distill, and age their own distillate, but then they use small barrels or poor quality cooperage, and generally have a "set it and forget it" mentality when it comes to aging their stock, with no regard to maturation conditions, or to proper amounts of humidity or temperature for the products they are making, etc. Sure enough, they've fermented and distilled their own product, but perhaps they haven't taken the time and had the patience to properly clean and sanitize their fermentation tanks, so that nasty bacterial contaminations from lactobacillus or acetobacter set up, or if they use a pot still to make Bourbon, they don't know how to properly make the cuts so that when their Bourbon matures, it won't taste like an oak stick with alcohol, etc. Just because they have a pot still, they're a small distillery, and make their own distillate, does this really mean that they are "craft," in that they are meticulous in their production details, have the patience to do things properly, and to age products for a truly proper amount of time, and to insure quality, and aren't just trying to push unfinished product out the door because they didn't do their business plan right, etc.? 

 

I know all of this stuff has been addressed ad nauseam over the years, and the different philosophies of what constitutes "craft" have their proponents on every side of the fence. Just my two cents on the matter......

 

Cheers,

Nancy

 

 

Legal definitions of craft refer to size and output. You however have just talked about what really matters.

[BottledInBond]

@Whiskey Bender that’s very eloquent commentary.
 

Lots of gray areas in this topic. For example, Barrell may be small enough in terms of what it produces/sells that people may think of them as craft. Although they primarily (entirely?) source from large producers that would not be considered “craft”. So does Barrell become “craft” based on their barrel selection, maturation decisions, and blending? Maybe. But Barrell also puts out barrel picks sourced from places like Dickel. I have a hard time considering that to be a “craft” product just because they selected the barrel and bottles at cask strength. 
 

If we want to focus on the art of maturation, barrel selection, and blending, would Four Roses LE Small Batch not be considered a “craft” product, even though it was distilled by a major? 
 

Those are some of the problems that I see. There are idiots that point to many NDPs as being “craft” just based on their marketing. Oh really, you think WhistlePig is “craft” because they blabber about their farm in Vermont? Not to pick on WP, but once again they release single barrels sourced from majors and slap their labels on it. No blending there. 
 

I think there is a lot more “craft” that went into, say, WTMK Decades than a NDP single barrel release of MGP juice, for another example. 
 

Getting past the marketing BS and gray areas of what craft is or isn’t, for the newer and smaller producers distilling their own juice, I hate to say that I’m in the negative camp on most of them still. I’ve said it before but I think the general population loves the craft beer renaissance and love how new breweries seem to be pushing the envelope and coming out with best products on the market, etc. and they tend to think “hey these craft distilleries must be doing the same to that industry”. When in fact, most craft whiskey is too young, is aged in stupid mini barrels, isn’t necessarily aged in the right climate to make ideal whiskey, is being made by people with no real experience, and is overpriced. 
 

Cheers to the few good ones that are actually making a good product, I wish them well. I’m just not going to spend good money on bad whiskey to “support” startups just based on principal. I anticipate a flooded market for used stills and fermenters in upcoming years as consumers sort out which of the new producers deserve repeat purchases or not based on how their juice actually tastes. 

[StarSurfer55]

Thanks to everyone for their comments and particularly to WhiskeyBlender  for her comments on craft.  As the son of a carpenter that taught me that you must first master your craft before you can do the “art”, I appreciate the skill, knowledge and experience required to consistently blend a product.  I have carried these lesson into my own career as a microbiologist a and have always appreciated the fermentation scientist that I worked with and their dedication to their ability to manipulate producer strains to increase not only production but to also optimize the specific end product of that fermentation product.  I also recognize that the legal definition of craft is often tied legally to production quantity as Bell’s Brewery had to get the michigan law changed as they increase their production.  

 

I don’ have an issue with a having a definition of a Craft blender that is different from a craft distiller as it would provide some clarity for both the enthusiast and the consumer.  As a pharmaceutical scientist that is used to reading the CFR, I can tell you that those that have not mastered their craft look at the federal regs as a rulebook to be followed strictly while those that are experts see the federal regs as a framework to be interpreted.  The latter group is a lot more creative and is much more successful in bringing innovative products to market.

 

Again, thanks for all the comments.  As usual, this group always has a thoughtful and passionate response.

[WhiskeyBlender]

@flahute, my guess is that you would agree with me (but I don't want to put words in your mouth!), but I think it is unfortunate that the legal definitions for craft have to do with size and output, and NOT on the science and art of creating something truly of exceptional quality.

 

 

 

@Bottled-in-Bond, I don't think that the term "craft" out to be just tied in the maturation and blending side of things at all. While I know this doesn't incorporate the legal definition of craft regarding size and output, I personally happen to believe that the term "craft" should be tied to doing things by hand, meticulous attention to detail in the creation of something, and making sure that all the QA/QC protocols are met to consumer expectations. So along those lines, I think that products that come from distilleries such as Four Roses (i.e., Small Batch) or WTMK Decades are without question more "craft" than a product that fermented, distilled, aged, and mingled by a small producer who rushes something out the door and does not pay attention to QC.

 

There's a class I teach for distillers called "Nosing for Faults," which takes a look at many of the possible faults that can occur in creating a distilled spirit, going from raw ingredients all the way through fermentation, distillation, maturation, water reduction/proofing from barrel to bottling, process and product transfer, to post-production. While I've had people from the large Bourbon distilleries take this class with me over the years when I'm teaching it at Moonshine University in Louisville, KY, the class is mostly geared at small distilleries who either don't have the budgets for a 1st rate QA/QC program, or who don't know how to do it. Well, once I had two distillers in the class who were from the same small distillery who claimed that they didn't have time to have such a program because "they were too busy making whiskey." Heck, they couldn't even find five minutes of their day to check their incoming grains with the very simple tests for checking mycotoxins! I was in absolute shock. Just my two cents, but if you don't have time to check QC throughout the entire production process, you're probably in the wrong business and should find another line of work.

 

@Starsurfer55, thanks for bringing this topic to light again! I always appreciate these kind of heady discussions on here, and I find it enlightening to read other points of view that I've never considered. 

 

Cheers,

Nancy

Edited September 7, 2020 by WhiskeyBlender

[flahute]

2 hours ago, WhiskeyBlender said:

@flahute, my guess is that you would agree with me (but I don't want to put words in your mouth!), but I think it is unfortunate that the legal definitions for craft have to do with size and output, and NOT on the science and art of creating something truly of exceptional quality.

 

You KNOW that I agree with you on this!

 

You've mentioned those two guys too busy making whiskey to do basic QC before and boy do I feel sorry for their customers who support them on the basis of supporting "craft" and "local".

[WhiskeyBlender]

1 hour ago, flahute said:

You KNOW that I agree with you on this!

 

You've mentioned those two guys too busy making whiskey to do basic QC before and boy do I feel sorry for their customers who support them on the basis of supporting "craft" and "local".

@flahute, preach it Brother, testify!  I know that you and I are definitely of like mind on such things, so I saw fit to include you in. 

 

For the life of me, I wish I could remember who those two distillers were. I want to be professional enough not to say who they are even if I can remember, but I'm really curious as to whether or not they're still in business. My guess, with that kind of attitude towards QA/QC, they probably didn't last too long. 

 

At any rate, hope you Gents have had a good Labor Day weekend! 

 

Cheers,

Nancy

Edited September 8, 2020 by WhiskeyBlender

[StarSurfer55]

Whiskey blender

 

just a question as you mentioned mycotoxins.  Are aflatoxins a problem in grains used fro distillation.?

[WhiskeyBlender]

@StarSurfer55, yes, aflatoxins in grains used for distillation can certainly be a big problem. Not that it happens all the time, but it isn't uncommon either. All the big distilleries know to check for it before accepting corn or other grains. A lot of craft distilleries that use grain aren't even aware that they SHOULD be checking for it before receiving their grain. 

 

That said, even if it isn't in the grain upon arrival at a distillery, it can still form due to poor storage conditions. That's why its important to test for it before fermentation. 

[StarSurfer55]

Thanks.  I would be concerned about aflatoxins as they are known carcinogens.  Do they survive the fermentation and distillation process.  Moldy grain is alway a problem and one which every large animal veterinarian is well aware of.

 

 

[WhiskeyBlender]

20 hours ago, StarSurfer55 said:

Thanks.  I would be concerned about aflatoxins as they are known carcinogens.  Do they survive the fermentation and distillation process.  Moldy grain is alway a problem and one which every large animal veterinarian is well aware of.

 

 

@StarSurfer55, the negative aroma certainly can survive the fermentation and distillation process, but I would doubt that the aflatoxin itself survives. 

[StarSurfer55]

W

8 hours ago, WhiskeyBlender said:

@StarSurfer55, the negative aroma certainly can survive the fermentation and distillation process, but I would doubt that the aflatoxin itself survives. 

whiskey blender. I looked it up and found an article that addresses it. It seems you need at least 150 C for the level of mycotoxins to be significantly reduced.  So would suspect that if there is a smell from aflatoxins, then they are still present.  

[WhiskeyBlender]

On 9/9/2020 at 5:55 PM, StarSurfer55 said:

W

whiskey blender. I looked it up and found an article that addresses it. It seems you need at least 150 C for the level of mycotoxins to be significantly reduced.  So would suspect that if there is a smell from aflatoxins, then they are still present.  

@StarSurfer55, wow, that's surprising, but incredibly interesting as well that they could still survive! Would you mind to send a PM to me with the info for that article? I'd love to read up on that. I'm always open and excited about learning new info. 

 

Cheers,

Nancy

[B.B. Babington]

aspergillus does not survive, but aflatoxin itself is robust.  aflatoxin is product of aspergillus.  aflatoxin is a large molecule and would not come over in distillation.  however, aspergillus can grow in the barrel.  1st run whiskey should be very low in aflatoxin, BUT 2nd run using used barrels can see significant amounts.  

 

this is old news for the folks that can tell you about aflatoxin levels in corn chips, peanut butter, etc.

 

and you will not smell aflatoxins, fungal funk, yes.

 

On 9/12/2020 at 7:44 PM, WhiskeyBlender said:

@StarSurfer55, wow, that's surprising, but incredibly interesting as well that they could still survive! ...