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COLA approval for Label problem...

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COLA approval for Label problem...

Postby Boomtown » Wed Jan 06, 2016 5:04 pm

We've hit a snag that is simply choking us. I sent a PM to respected member, then realized several of us may have had these problems. So I think I'll bounce this out there and see if anyone will PM me and help me work through this hic-up.

We're struggling with the COLA application about the language on our label. We are trying to get an approval for our White Whiskey ( Misty Morning) and we got the following feedback from TTB today:

From TTB: "Your label contains conflicting class and type statements. " "Reason Additional Information As an attachment, please further explain/clarify the statement and/or graphics shown on the label." What does this mean? (see the language we submitted below) The graphic is simply a small logo icon of a rising sun we had a graphic artist do...(i.e. "misty MORNING" , right?)

"Please provide documentation from the producer (on producer's letter) verifying the "white" whiskey claim (see puffery) so that we may determine if the product meets the "white" claim. " What is a 'puffery'? What does the 'meets the "white" claim" ' mean, its a clear whiskey....I didn't see a classification for a White Whiskey and a short spin through google shows the term commonly used for other peoples products....what are they doing that we didn't do?

"You must state how long product is aged. " Duh...it's a white whikey, not aged in oak. We hold it 4 days in open SS barrels, but that is not 'ageing' it, is it?

"In order to use the white whiskey claim, you must also provide the age statement on label. " Seriously, I don't see that statement appearing on anyone elses white liquor labels.


This is our language being challenged:

"Misty Morning is Craft distilled whiskey carefully prepared from an 85-year old family recipe and originally made before Prohibition. It demonstrates the art and traditional flavors of whiskeys made and shipped down river to New Orleans during the 1700’s and 1800’s. Re-created using modern distilling arts and equipment, it stays true to its heritage by presenting a unique and enchanting experience for people who appreciate good white whiskey. "


If you can help, please just call give me a call, or send me a phone number where I can call you, maybe this can be resolved simply?

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Re: COLA approval for Label problem...

Postby punkin » Wed Jan 06, 2016 5:42 pm

Bet it's the word whiskey no the word white they are challenging.
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Re: COLA approval for Label problem...

Postby Zymurgy Bob » Thu Jan 07, 2016 12:16 pm

I don't have any help for you, but I appreciate your putting this up on the forum. I'm helping a friend start a tiny local distillery, and all insight and information is welcome. She's also still in the approval process, but she's got her labels accepted (I think :? ).
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Re: COLA approval for Label problem...

Postby 3d0g » Thu Jan 07, 2016 7:00 pm

Usually the COLA hangup with white whiskey is the TTB doesn't want people thinking it's an officially recognized class of whiskey. By law, there's only one "white" whiskey - corn. Some workarounds that have passed the TTB include scrapping "whiskey", a la "White Dog", "Whitewater", etc or separating white and whiskey onto separate lines (though I've heard reports the TTB isn't allowing this one anymore).

Of course you know that technically, to call it (any) whiskey except for corn, it needs to at least pass through some new charred oak...
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Re: COLA approval for Label problem...

Postby Bushman » Fri Jan 08, 2016 7:51 pm

This article in Distillery Trail ties in with the subject:
http://www.distillerytrail.com/blog/str ... -105430637
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Re: COLA approval for Label problem...

Postby zedzedtop » Sat Jan 09, 2016 2:53 am

How about asking Chuck Cowdery? ADI forums?
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Re: COLA approval for Label problem...

Postby Smaug » Sun Jan 10, 2016 3:02 pm

Grim, Cotherman, Citrus Distillers, Little Chicago, Bierling and a couple few others on the SD forum prolly wouldn't mind shedding some light on the subject.
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Re: COLA approval for Label problem...

Postby sasquatch » Sun Jan 10, 2016 5:54 pm

Read the Acts and Statutes in the distillery's jurisdiction.
They should explain it all to you.

For example here is statutes from Canada on Whiskey.
http://www.inspection.gc.ca/food/labell ... =15#s31c15

Age Claims for Whisky

Claims for the age of whisky are restricted to the period during which the whisky was stored in small wood. Whisky other than Bourbon [B.02.022, FDR] and Tennessee [B.02.022.1, FDR] must be aged at least three years in small wood, except that any domestic or imported spirit added as flavouring need only be aged for two years [B.02.020(2), B.02.023, FDR]. Where Canadian Whisky has been aged in small wood for at least three years, any period not exceeding six months during which that whisky was held in other containers may be claimed with respect to the age [B.02.020(3), FDR]. For example, Canadian Whisky aged three and a half years in small wood and eight months in glass containers may claim an age of four years.
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Re: COLA approval for Label problem...

Postby sasquatch » Sun Jan 10, 2016 6:11 pm

Here is the USA codes.

https://www.law.cornell.edu/cfr/text/27/5.22

27 CFR 5.22 - The standards of identity.

§ 5.22 The standards of identity.
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. “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.

(1) “Vodka” is neutral spirits so distilled, or so treated after distillation with charcoal or other materials, as to be without distinctive character, aroma, taste, or color.

(2) “Grain spirits” are neutral spirits distilled from a fermented mash of grain and stored in oak containers.

(b) Class 2; whisky. “Whisky” is an alcoholic distillate from a fermented mash of grain produced at less than 190° proof in such manner that the distillate possesses the taste, aroma, and characteristics generally attributed to whisky, stored in oak containers (except that corn whisky need not be so stored), and bottled at not less than 80° proof, and also includes mixtures of such distillates for which no specific standards of identity are prescribed.

(1)
(i) “Bourbon whisky”, “rye whisky”, “wheat whisky”, “malt whisky”, or “rye malt whisky” is whisky produced at not exceeding 160° proof from a fermented mash of not less than 51 percent corn, rye, wheat, malted barley, or malted rye grain, respectively, and stored at not more than 125° proof in charred new oak containers; and also includes mixtures of such whiskies of the same type.

(ii) “Corn whisky” is whisky produced at not exceeding 160° proof from a fermented mash of not less than 80 percent corn grain, and if stored in oak containers stored at not more than 125° proof in used or uncharred new oak containers and not subjected in any manner to treatment with charred wood; and also includes mixtures of such whisky.

(iii) Whiskies conforming to the standards prescribed in paragraphs (b)(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”; for example, “straight bourbon whisky”, “straight corn whisky”, and whisky conforming to the standards prescribed in paragraph (b)(1)(i) of this section, except that it was produced from a fermented mash of less than 51 percent of any one type of grain, and stored for a period of 2 years or more in charred new oak containers shall be designated merely as “straight whisky”. No other whiskies may be designated “straight”. “Straight whisky” includes mixtures of straight whiskies of the same type produced in the same State.

(2) “Whisky distilled from bourbon (rye, wheat, malt, or rye malt) mash” is whisky produced in the United States at not exceeding 160° proof from a fermented mash of not less than 51 percent corn, rye, wheat, malted barley, or malted rye grain, respectively, and stored in used oak containers; and also includes mixtures of such whiskies of the same type. Whisky conforming to the standard of identity for corn whisky must be designated corn whisky.

(3) “Light whisky” is whisky produced in the United States at more than 160° proof, on or after January 26, 1968, and stored in used or uncharred new oak containers; and also includes mixtures of such whiskies. If “light whisky” is mixed with less than 20 percent of straight whisky on a proof gallon basis, the mixture shall be designated “blended light whisky” (light whisky—a blend).

(4) “Blended whisky” (whisky—a blend) is a mixture which contains straight whisky or a blend of straight whiskies at not less than 20 percent on a proof gallon basis, excluding alcohol derived from added harmless coloring, flavoring or blending materials, and, separately, or in combination, whisky or neutral spirits. A blended whisky containing not less than 51 percent on a proof gallon basis of one of the types of straight whisky shall be further designated by that specific type of straight whisky; for example, “blended rye whisky” (rye whisky—a blend).

(5)
(i) “A blend of straight whiskies” (blended straight whiskies) is a mixture of straight whiskies which does not conform to the standard of identify for “straight whisky.” Products so designated may contain harmless coloring, flavoring, or blending materials as set forth in 27 CFR 5.23(a).
(ii) “A blend of straight whiskies” (blended straight whiskies) consisting entirely of one of the types of straight whisky, and not conforming to the standard for straight whisky, shall be further designated by that specific type of straight whisky; for example, “a blend of straight rye whiskies” (blended straight rye whiskies). “A blend of straight whiskies” consisting entirely of one of the types of straight whisky shall include straight whisky of the same type which was produced in the same State or by the same proprietor within the same State, provided that such whisky contains harmless coloring, flavoring, or blending materials as stated in 27 CFR 5.23(a).
(iii) The harmless coloring, flavoring, or blending materials allowed under this section shall not include neutral spirits or alcohol in their original state. Neutral spirits or alcohol may only appear in a “blend of straight whiskies” or in a “blend of straight whiskies consisting entirely of one of the types of straight whisky” as a vehicle for recognized flavoring of blending material.

(6) “Spirit whisky” is a mixture of neutral spirits and not less than 5 percent on a proof gallon basis of whisky, or straight whisky, or straight whisky and whisky, if the straight whisky component is less than 20 percent on a proof gallon basis.

(7) “Scotch whisky” is whisky which is a distinctive product of Scotland, manufactured in Scotland in compliance with the laws of the United Kingdom regulating the manufacture of Scotch whisky for consumption in the United Kingdom: Provided, That if such product is a mixture of whiskies, such mixture is “blended Scotch whisky” (Scotch whisky—a blend).

(8) “Irish whisky” is whisky which is a distinctive product of Ireland, manufactured either in the Republic of Ireland or in Northern Ireland, in compliance with their laws regulating the manufacture of Irish whisky for home consumption: Provided, That if such product is a mixture of whiskies, such mixture is “blended Irish whisky” (Irish whisky—a blend).

(9) “Canadian whisky” is whisky which is a distinctive product of Canada, manufactured in Canada in compliance with the laws of Canada regulating the manufacture of Canadian whisky for consumption in Canada: Provided, That if such product is a mixture of whiskies, such mixture is “blended Canadian whisky” (Canadian whisky—a blend).
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