Do you see something wrong with the above labels? All of them have “fancy” commodity statements, rather than one that is more stripped down. A plain commodity statement would be something like DISTILLED FROM GRAIN rather than DISTILLED FROM FRENCH WHEAT, as on the Grey Goose label above.

On the one hand, there are many label approvals, such as the above. On the other hand, TTB recently rejected DISTILLED FROM NEW YORK GRAIN and said it must appear as DISTILLED FROM GRAIN instead. Can both the approvals and the rejection possibly be right? Between the two, what do you think is more right? This can be critical because most vodka and gin labels must have a compliant commodity statement, to show the commodity from which the base spirits are distilled.

The examples above are Heart of the Hudson Vodka (NY Apples), Tuthilltown Vodka (75 pounds of Hudson Valley Apples), Grey Goose Vodka (French Wheat), Core Vodka (Hudson Valley Apples), Bootlegger Vodka (American Grain), and China Beach Vodka (California Grapes). Other examples are Cold River Gin (Maine Potatoes), Soft Tail Vodka (Washington State Apples), True North Vodka (Michigan Rye), and Flathead Vodka (Idaho Sugar Beets).

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If ever there is a contest, between wine and spirits, I wonder which has been made from a greater variety of foodstuffs over the years. Here is a budding list of commodities from which wine is commonly or not so commonly fermented. Perhaps we will someday prepare a similar list of commodities from which spirits are commonly or not so commonly distilled. On such a list we’d have to include vodka made from milk. But that one is from the past, and so today to the list we add vodka distilled from honey. Comb is made by StillTheOne Distillery in Port Chester, New York. Comb is a rare brand that has a Facebook site but no other website.

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The people that set up the pre-market approval system for alcohol beverages probably did not anticipate that, sooner or later, it would come to this. Here is Erection Rum, imported by Data Commodities of Las Vegas, Nevada.

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Here it is. What all the controversy is about. EtOH. It is quite possibly the most popular psychoactive substance in the world, running neck and neck with caffeine, at least among substances that don’t require a prescription or jail time.

EtOH is otherwise known as ethanol or alcohol or ethyl alcohol. Ethanol is a contraction for ethyl alcohol and ethyl derives from “ether.” This particular EtOH is bottled by Ballast Point Spirits of San Diego, California.

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This approval shows a tremendous amount of change in eight short years. First of all, it is hard to imagine that the Bureau would ever allow the term “vodka” on a beer label. Somehow I don’t think that would fly in this day and age. Further, the qualification seems to mandate the use of this term, in a particular way. The qualification suggests that the arrangement of the words may lead to controversy, rather than the reference to vodka and a famous vodka brand on a beer label. Pages 12-22 of this document show the controversy.

Second, the product is gone. So is the named agency (that is, the label functions have moved from ATF to TTB). So is the person that approved it. Judy was tremendously helpful and probably had many good reasons to approve this label, in a different era. I wouldn’t want to mention the person, but for the fact that the name is right there and the memories are good.

This is also a good example of a “use-up.” The approval tends to say the label is not ideal but the agency will allow it to be used for six months only. I believe TTB/ATF has allowed use-ups for many, many decades. It is difficult to imagine other agencies allowing this privilege, such as FDA allowing a dubious label but only for a few months, or Customs allowing a dubious origin statement for a few more months. For these reasons, I wanted to highlight the label before it fades further into history.

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L’Chaim Vodka is distilled no less than 18 times. In an excellent website (www.theendofvodka.com), VeeV Acai Liqueur pokes fun at the vodkas distilled 3, 5, 23, 570 times. The site is funny, pretty, and makes a good point. It tends to suggest that after the first couple of distillations, and after pushing the spirit past 190 proof, it’s a fairly pointless exercise to distill it more.

Virtuoso Distillers, of Mishawaka, Indiana, is undaunted. In box 19 of the L’Chaim approval, Steven Ross patiently explains that the vodka is distilled 18 times. TTB frequently asks for such a confirmation, when the label sets forth the number of distillations or filtrations. This is odd because the label already claims it under penalty of perjury, the certification doesn’t seem to make it any more likely to be true, and it would seem to be a minor point in any event (for the reasons suggested by VeeV).

Mr. Ross has a lot more going on, on this label. He further explains that L’Chaim (or, “To Life”) is similar to “cheers,” carefully avoiding any suggestion that it’s about health. This is not a small matter because, prior to this approval, the term was rarely used in a prominent way on US alcohol beverage labels. Mr. Ross explains that the letters that spell L’Chaim also “add up to the number 18.”

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TTB does not usually allow vintage-, varietal- or appellation-type claims on distilled spirits labels. The rationale is that these concepts tend to be more appropriate for wine. But here are a couple of notable exceptions. Roth Vodka displays “California” in much the manner of an appellation. This vodka also happens to be distilled from grapes, and has something close to a vintage date on the front label. The latter apparently went too far, and TTB directed Roth to remove the date.

In some ways, the Primo Vodka label goes a bit further. It mentions a specific grape type, along with the source of those grapes. One side tends to argue that these claims are truthful and verifiable. TTB tends to argue that characteristics such as vintage, varietal and appellation are subtle to begin with; distillation (let alone distillation to the point of neutrality) tends to obliterate such characteristics; and it’s misleading to suggest otherwise. Do consumers need this protection?

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It’s a wonder that Red Bull (of Austria) has not yet come out with with an alcohol beverage. It would be likely to be a smash, in that the product is so very popular as a mixer.

Perhaps things are going so well with the energy drink that there is no need to mess with it. But more likely, these two products beat the Austrians to the punch. Miller Brewing Company has approvals for Red Bull Malt Liquor going back at least as far as the early 1980s. Likewise, Majestic Distilling has approvals for Red Bull Vodka going back to 1990 or so.

This Dog Style Vodka is one of the few TTB products to make explicit reference to the famous energy drink.

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One of the main warnings says, “Do not use this product for flaming dishes or drinks.” It’s a little bit like a Maserati with a warning that you should not exceed 55 mph.

We kind of thought flaming drinks were one of the main purposes for this product. If not, we went in search of the more conservative uses for this product. We found very little, with no trace of this product on Bacardi’s US website. This group seems to have no idea what to do with it either.

At an even higher concentration of alcohol is Golden Grain Grain Alcohol. It is 95% alcohol and is also plastered with warnings throughout the front, back and neck labels. This is a rare example of TTB allowing warnings other than the specific health warning mandated by Congress (see this for an example of a warning not allowed). It’s hard to say the extra warnings are not warranted here.

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Maybe N. Bergman or L. Fogelman can explain why there are so many distilled spirits plants in New York, all of a sudden. Here are three, and all are distilling vodka from apples (rather than the much more common and less expensive distillation from grain).

Tuthilltown Spirits makes Heart of the Hudson Vodka (above). It is distilled from 100% New York apples. Eighty miles up the Hudson River, Harvest Spirits makes Core Vodka. They purport to distill only from Hudson Valley apples, in small batches.

Third, there is Beak & Skiff Vodka, also distilled from apples, over near Syracuse. Larrie Laird (the dean of distilling apples in the US) once explained that it is immensely expensive to produce high-proof spirits from apples or any other fruit. It can take well over 25 pounds of apples to make one bottle.

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