Archive for September, 2010
On April 6, 2000, ATF issued a policy on the use of hemp or hemp components in alcohol beverages and on the use of the term “hemp” or depictions of the hemp plant on labels for alcohol beverages. The policy does not ban the use of hemp in alcohol beverages, but was created to assure that beverage alcohol products do not contain a controlled substance (tetrahydrocannabinol (THC)). ATF also determined that the appearance of the word “hemp” or depictions of hemp plants on labels was likely to create a misleading impression as to the true identity or quality of the product. As of this writing, there are no approved certificates of label approval for products containing hemp.
Slowly but surely, however, in recent months various beers with hemp are starting to re-emerge and three of them are highlighted in this post. For the uninitiated, hemp happens to be a member of the cannabaceae family, a cousin of hops and close kin of marijuana (or cannabis). Above is O’Fallon’s Hemp Hop Rye, an amber ale brewed with hemp seeds and approved earlier this year. The label mentions the hemp, and has a little picture of the hops and rye — but the hemp or hemp seed imagery seemed to be missing (until we added it to the image above). According to a St. Louis Riverfront Times review the product “contains three kinds of malted barley, two types of rye, three varieties of hops and toasted hemp seed.”
TTB applied several hemp-specific qualifications to this and the other hemp approvals. TTB said:
- This label may not be used on a product that contains a controlled substance.
- Hemp component(s) must be tested in the U.S. for the presence of controlled substance(s) each time component is imported and results must be maintained on your premises for inspection.
- A detailed description of the method of analysis used by the U.S. lab to test for controlled substance must be maintained on your premise for inspection.
A second example is Humboldt Brown Ale Brewed with Hemp. It is brewed by Firestone Walker of Paso Robles, California. This approval also happens to add “This malt beverage may not have been produced with adjuncts (additives) except those that do not remain in the finished product.”
Our third example is Rogue Epoch Days Ale Brewed with Hemp Seeds. It is brewed in Newport, Oregon and happens to include a highly detailed ingredient list of a sort that is fairly rare on alcohol beverage labels.
Boston Beer has finally answered the big question eluding so many since the 1980s — “where’s the beef?” It’s right here, in the beer bottle. Burke in the Bottle is “Ale Brewed with Beef and Spices with Molasses Added.”
Throw in a side of broccoli and we are all set for the evening. If this guy and Sam Adams think it’s worth drinking, who are we to cast aspersions?
Well it’s not exactly the Elvis-type decanter so popular in the age of Mad Men, but here is a bottle that more or less breaks the conventional mold. Republic Tequila is imported by Momentum Brands, of Austin, Texas. The Jim Beam Club site has a good collection of, well, collectible decanters, and we wonder if Republic is sufficient to make the cut.
This is an example of a “distinctive container” (as at item 18(c) of the approval) and helps explain why the familiar COLA form happens to mention bottle approval (and not just label approval) in the name of the form. Thanks to a friendly person in Texas for sending this photo.
This post will start short but is likely to grow long over time. Very long. We will try to show the enormous range of foodstuffs from which wine is produced. With each post we will add to the list, and I predict it will grow way past 50 60. Today we add Persimmon wine to the list.
- Avocado wine
- Banana wine
- Cantaloupe wine
- Dandelion wine
- Elder flower wine
- Fig wine
- Grape wine
- Jasmine fruit wine
- Kiwi wine
- Linden flower wine
- Lychee wine
- Mangosteen wine
- Marionberry wine
- Onion wine
- Pomegranate wine
- Pear wine
- Pepper wine
- Persimmon wine. Made by Buck Mountain Winery of Doe Run, Missouri.
- Pineapple wine
- Rhubarb wine
- Strawberry wine
- Tomato wine
- Watermelon wine
On this label, VODKA appears to be 2-4 times more prominent than RASPBERRY FLAVORED VODKA. This disparity was apparently too much, and tipped the scales toward the surrender of this and many other Rokk brand flavored vodka labels recently. For quite some time, TTB has been concerned about the relative prominence of this coveted term (vodka) — especially on products that are not technically “vodka.” The federal standard for vodka is quite restrictive and surely allows for nothing like raspberry flavor. In fact, only a bit of sugar and citric acid are allowed in true “vodka,” nothing more. If anything more is added, the product jumps over to what TTB views as an entirely different category such as a flavored vodka or vodka specialty.
This approval (issued February 17, 2010) shows Diageo surrendering one of many Rokk labels. This use-up approval (issued September 2, 2010) shows what TTB wants Diageo to change. The most relevant TTB qualifications, toward the center of the approval, say:
(When new labels are printed the class and type designation Raspberry Flavored Vodka must appear conspicuous on the label and the reference to Vodka of Sweden standing alone must be deleted.)
(The reference to Rokk Raspberry Vodka and Rokk Vodka in the text on the back label must be further qualified to include the word Flavored with the designation.)
TTB has been quite concerned about word proximity, especially on spirits labels, in recent months. For example, certain terms must be near “absinthe.” In other instances (under the current interpretation), the type (such as Tequila) must be “separate and apart” from the brand name (such as Jose Cuervo), and all of it must be apart from other data.
TTB apparently explained all this to Diageo’s satisfaction but perhaps TTB should explain this evolving standard to other affected parties before they get surprised by their own rejections and surrenders.