Posts Tagged ‘rejections’
The Triple Sec Lobby
The highly secretive and powerful Triple Sec lobby has struck again — this time to require at least one drop of triple sec in certain alcohol beverages. Google it as much as you wish, and you will find little about this uber-secret institution, rumored to have strong ties leading all the way back to France. That’s because it’s secret. Some even say that Sen. John Kerry, with his thinly disguised sympathies for many things French, is Triple Sec’s man in Washington.
On a more serious note, for many years, TTB has required at least some triple sec in products that purport to be margaritas. The policy is here, at page 13 (scroll down to Margarita). The policy is in TTB’s “Beverage Alcohol Manual” for spirits. The BAM can be a handy resource to explain and supplement the regulations. Sometimes, as here, it goes considerably beyond what the law or regulations say. In this particular case, it seeks to mandate that every margarita must have: “Tequila, triple sec and lime or lemon juice or oil or natural lime or lemon flavor.” Here is a recent example of TTB seeking to enforce the rule.
Does such a rule make any sense in this day and age of scarce resources? What is the worst that would happen if such a rule went away? Some may say the rule does not go far enough — and should similarly apply to malt beverages, wines, cocktails prepared at retail premises and even homes. If you have any doubt about the hushed-up threat presented by this rule (explaining how to make various cocktails), do not forget that the same rule also requires just a little bit of cream — or crème as some call it — in a Grasshopper or Pink Squirrel.
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Class & Type Must Stand Alone
In the above example, it is not sufficient to have VODKA on the front label. Or, the right size. In addition, it needs to be “separate and apart” from other matter. TTB has gotten more strict about this over the years. The above rejection is from a few days ago. The vodka label is from many years ago, to show the movement in the policy, or the enforcement of the policy.
TTB is quite concerned about word placement and proximity. For example, “absinthe” must appear next to other words, as here. Vodka may not, as above. It is important to understand the various proximity rules, because they can lead to unpleasant surprises, and because they extend from spirits to beer and wine. It is probably not okay to bury the word “chardonnay” amidst a sentence singing its praises. It is probably not okay, in most instances, to affix several words before and after BEER.
The rule can be difficult because it’s not always clear how much separation is required (A few spaces? A few line breaks?). It’s not always clear why some terms get treated differently (such as “Silver Rum” or “Cream Liqueur”). It is easy enough to add an extra class/type statement to the front label, to avoid any difficulties (such as adding VODKA to the above label, on its own line) — but only if you know the rule early enough.
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Age Range on Wines
This Malvira red wine happens to mention that the Barbera d’Alba blend is “aged in French Oak barriques … for 18-24 months.” Is there anything so troublesome about that? Maybe so. On a similar label (with a different age range), the above rejection shows that TTB would prefer that wine labels show the actual amount of age, rather than a range or guesstimate.
TTB did not cite any specific authority in the rejection above, but 27 CFR 4.38(f) would make it hard for the importer to win this argument. It says:
(f) Additional information on labels. Labels may contain information other than the mandatory label information … if such information complies with the requirements … and does not conflict with, nor in any manner qualify statements required by this part. In addition, information which is truthful, accurate, and specific, and which is neither disparaging nor misleading may appear on wine labels.
The stated range (six months on one and two months on the other) may be accurate and non-disparaging, but it’s not especially specific.
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Charity Labels
Here are a few charity-themed alcohol beverage labels. They are becoming more common, to the point where TTB does have a specific policy. In general, of course the charity language has to be truthful and non-misleading — but also, it needs to have a bit of specific information (such as the name of the charity).
Vets Vodka is bottled by Terressentia of North Charleston, South Carolina and benefits the National League of Families (POW-MIAs).
Hope Wine is bottled by Sonoma Wine Company of Graton, California and benefits “our troops.”
Third, Charity Case wine is made by One True Vine, LLC of St. Helena, California and benefits “charities serving children and families in and around Napa County.”
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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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