If, perchance, your intended cocktail is on the list, TTB will be rather fierce abo… The TTB's goal is to ensure you're legally qualified to operate your distillery and that you'll do it safely and fairly. These changes are designed to streamline processes and provide extra flexibility for alcoholic products. Attorneys for Label Approvals in Boise We Work Directly with Business Owners & Designers. If you’ve been paying any attention in the last year, you’ve heard of all the hubbub about correctly labeling whiskey, and more specifically bourbon. Visit TTB's Formulation pages to learn more. Lighthearted conversation about news from the store. It also adds specific examples at the bottom of how to label blended whiskies. Despite this, the labeling of some beers and some wines are regulated by the FDA. I hope you enjoyed this trip through the TTB Standards Of Identity for Whiskey in Plain English. This seems to suggest that this now applies to any whiskey product less than 4 years old. For many alcohol beverage products, TTB requires a product evaluation to determine whether a proposed label identifies the product in an adequate and non-misleading way. Is an age statement required on a whisky label? The responsible industry member must continue to ensure that the mandatory information on the actual labels is displayed in the correct type size, number of characters per inch, and on a contrasting background in accordance with the TTB labeling regulations, 27 CFR parts 4, 5, 7, and 16, as applicable. The BATF, or the Bureau of Alcohol, Tobacco and Firearms, now is called Alcohol and Tobacco Tax and Trade Bureau and goes by the shortened, TTB. This list does not do an especially good job of recognizing that cocktails come and go like fashion, and there are many modifications upon even the most enduring themes. As Chuck notes it appears that by restating the regs, the agency is making clear that they may no longer tolerate the misrepresentations of many distillers. Put into a charred new oak container no higher than 125° proof (62.5% ABV). TTB is also amending the definition of “brand label” to remove the requirement that the brand label be the principal display panel. Thus a bourbon must only be stored in “charred new oak”, period, regardless of what you want to call it. We’re looking at you Templeton Rye. Includes the definition of “Bourbon Whiskey” but additionally: Is required to be … Note: The TTB Public COLA Registry provides access to information about Certification/Exemption of Label/Bottle Approvals (COLA), which TTB issues on Form 5100.31. Freelance writer, student of life. This is where the TTB comes in. Currently, TTB allows the term “Tennessee Whisky” to appear on labels, even if the product meets a more specific standard of identity, such as for bourbon whisky.” Background- Currently a distiller can bottle a spirit that meets all the legal requirements for bourbon yet they can chose not to put the word “bourbon” on the label. A major hurdle that most wine producers hit is the dreaded label design. There’s already a set of rules in place about what type of whiskey can be labeled as bourbon. Even the back of the production report says 'grain and grain products'. Just like misleading aging statements, it has become a common misrepresentation for distillers to incorrectly label a spirit as “bourbon”. Both Jim Murray and I feel quite strongly about this. TTB audits distilleries and tests for the accuracy of alcoholic content. Louisville. Wine Labeling. Aged not less than ____ years. Is an age statement required on a whisky label? TTB is amending existing § 5.40(a)(1) regarding statements of age for whisky that does not contain neutral spirits to provide that multiple barrels may be used and to provide that the label may optionally include information about the types of oak containers used. In the current regulations, when a whisky meets the standard for a type of whisky, it is unclear whether the label must use that type designation or may use the general class “whisky” on the label. The terms apply to mixtures of Whiskeys of the same type. Alcoholic beverages with prescribed standards in Division 2 of Part B of the FDR include whisky, rum, gin, brandy, liqueurs and spirituous … In the 2018 Proposal, TTB proposed to require that, where a whisky meets the standard for one of the types of whiskies (e.g., … Can I simply label the product as having been “Aged for less than 4 years”? Down to the hour if applicable. First off, TTB keeps a quaint old list of “recognized cocktails” here. TTB is amending existing § 5.40(a)(1) regarding statements of age for whisky that does not contain neutral spirits to provide that multiple barrels may be used and to provide that the label may optionally include information about the types of oak containers used. This is critical. The regulations at 27 CFR 5.40(a)(5) provide that optional age statements must appear in the same form as required statements. The requirements for the declaration of alcohol by volume apply to foods generally but for the purposes of this guide the requirements will be expressed as for alcoholic beverages only. ( Log Out /  The TTB also has an online permits tutorial that covers the process and key terms and phrases to be aware of.. See 27 CFR 5.40 and Chapter 8 of the Beverage Alcohol Manual (BAM) for additional information about optional age statements. Those TTB regs say 'from grain' not 'from only grain'. The beers and wines that are subject to FDA’s labeling jurisdiction […] Bourbon. Aged not more than ____ years. The statement “aged for less than 4 years” does not satisfy the requirements of 27 CFR 5.40 for an age statement, and it creates a misleading impression as to the age of the product. How should age be stated if the whisky consists of a mixture or blend of whiskies with different ages? The age may be understated, but the age may not be overstated. TTB solicited comments on this proposal as a potentially restrictive change to the regulations, because in the current regulations, when a whisky meets the standard for a type of whisky, it is unclear whether the label must use that type designation or may use the general class “whisky” on the label. The Federal Alcohol Administration Act (“FAA”) regulates the interstate and foreign commerce of wine, spirits, and malt beverages and bestows general authority to oversee these products to the TTB. “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. See 27 CFR 5.40(e)(2) for rules applying to age, maturity, and similar representations. 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. What are examples of age statements that are not acceptable? You can read more about how to qualify for a distilled spirits permit. TTB has not reviewed this label for type size, characters per inch or contrasting background. The core aging requirement that defines a whiskey as straight is if the distillate has spent at least two years stored in charred new oak barrels, except corn whiskey which must use uncharred or used oak barrels. Change ), You are commenting using your Twitter account. Specially-Finished Whiskey is a growing category, I can testify to this by the increase of such products to cross my desk in the last couple years. Editor’s Note: With the clock winding down towards June 26 on the public comment period for the TTB proposed modernization of labeling new rules, the American Single Malt Whiskey Commission, a trade group representing American distilleries producing American single malt whiskeys, has chimed in with their thoughts. The TTB regulations at 27 CFR 5.40(a) require an age statement on the label of any whisky that has not been aged for at least four years. What are examples of acceptable formats for age statements? Mash must contain at least 51% corn (Bourbon Whiskey), rye (Rye Whiskey), wheat (Wheat Whiskey), malted barley (Malt Whiskey) or malted rye grain (Rye Malt Whiskey). The TTB proposes defining grain as including “cereal grains and the seeds of the pseudocereals amaranth, buckwheat and quinoa.” Previously, I think this only applied to whiskies that have been labelled ‘straight’ that were less than 4 years old and any whiskey less than 2 years old. The age of the whisky must be stated in hours, days, months, or years, as appropriate. The following formats are acceptable: The recent TTB proposal to modernize spirits regulations added a host of new definitions for terms that are widely used but not defined in the regulations, including “cask strength,” “white whiskey” and “oak barrel.” Despite the voluminous nature of the TTB proposal, though, there are still a number of widely used terms that are not defined in the regulations, including the following: An age statement is optional for any whisky that is four years old or more, unless the label makes a representation as to age or maturity. Presumably in an effort to combat this, the TTB has come out with new phrasing for its guidelines. I suppose this is to prevent counting any aging in a barrel finished process. They aren’t perfect, and some don’t go far enough, but they are a good start at updating the regulations. 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