Posts Tagged ‘formulas’
A few weeks ago we wrote about moonshine and now we have occasion to write about its close relative, White Whiskey.
Products like the above have become quite popular within the past few years, for reasons well explained by Slate:
The term white whiskey is basically a marketing name for what distillers call white dog, referring to grain-based spirits that haven’t been aged in wood to improve their flavor. [Sometimes] it’s just called moonshine, but legal sales of white dog in recent years have helped upstart microdistilleries earn immediate revenue while their whiskies age. That’s because white dog can be bottled and sold immediately after being distilled without accruing any additional storage and aging expenses. The moonshine connection has been a useful marketing gimmick for hip urban bars, but there’s one considerable downside to white dog: It tastes horrible.
At first, TTB was skeptical and pushed back a bit (saying, for example, there is no such category in the regulations). But as the trickle became a deluge, TTB began to allow white whiskey products more freely. In the light of a large number of recent approvals, it becomes clearer that TTB chiefly wants WHISKEY and WHITE on two different lines — more like Beam and less like Death’s Door (as above). Less clear is whether such products need a formula approval (adding the formula step can add 4-5 weeks to what is already a 4-5 week project). Most of the recent label approvals do not refer to any formula approval, as in the following examples.
Formula not mentioned
Be careful about the five year rule as above and here. The rule says TTB formulas expire five years after approval. Not all formulas. Just the ones for imported products such as vodka, sake, and liqueur for example. This is in substantial contrast with TTB label approvals, permits, and domestic formulas. Generally speaking, they don’t expire unless the applicant changes something.
In our experience, TTB tends to explain the expiration date on the relevant formula approvals, but not in the regulations or widely elsewhere. An example is here. It can come as an unpleasant surprise, if you are seeking a new label approval more than five years after issuance of the formula approval, as in the case above. In the time period about 5-8 years ago, TTB would frequently allow a use-up in some cases where the formulas was expired. But, as suggested above, use-ups are much harder to get, in more recent years.