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Firestarter

Distinctive container? Box 18c of this approval says it is.

Kodiak Imports, of San Diego, California, has several TTB approvals for spirits products packed in containers that look quite a bit like fire extinguishers. If you stop and think about it, the brand name doesn’t exactly suggest that it puts out fires, and the back label points out that “This is not a fire extinguisher.” Then again, it does look a lot like exactly that. The website says “The multi award winning packaging looks like a fire extinguisher, complete with a locking pin, lever, and a nozzle through which Firestarter Vodka is poured.” Thank goodness it’s only 80 proof.

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distilled spirits specialty, vodka


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The Prominence of Vodka, Part 2


How big is your vodka?

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.

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flavored malt beverage, vodka


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Fancy Commodity Statements

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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Vodka from Honey

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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Manly Parts and Booze, Part 4

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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