Change ), You are commenting using your Google account. The TTB also has an online permits tutorial that covers the process and key terms and phrases to be aware of.. As Chuck notes it appears that by restating the regs, the agency is making clear that they may no longer tolerate the misrepresentations of many distillers. This seems to suggest that this now applies to any whiskey product less than 4 years old. The responsible industry member must continue to ensure that the mandatory information on the actual labels is displayed in the correct type size, number of characters per inch, and on a contrasting background in accordance with the TTB labeling regulations, 27 CFR parts 4, 5, 7, and 16, as applicable. I’ll put the new wording below it’s found in the FAQ section of the TTB site. You can read more about how to qualify for a distilled spirits permit. An age statement is optional for any whisky that is four years old or more, unless the label makes a representation as to age or maturity. Currently, TTB allows the term “Tennessee Whisky” to appear on labels, even if the product meets a more specific standard of identity, such as for bourbon whisky.” Background- Currently a distiller can bottle a spirit that meets all the legal requirements for bourbon yet they can chose not to put the word “bourbon” on the label. Straight Whiskey. A Charity Cocktail and Bourbon Tasting Event for Five Points of Life. Certain TTB terms and font sizing requirements can be tricky. Light whiskey is an unusual exception in that it must be distilled above 80% ABV and can be stored in uncharred or used oak containers. As noted above, age may be understated, but may not be overstated. ____ months old. TTB is also amending the definition of “brand label” to remove the requirement that the brand label be the principal display panel. COLAs in the registry have one of the following current statuses: approved, expired, surrendered, or revoked. Aged a minimum of ____ months. General Whisky Requirements • 27 CFR 5.22(b) • Distilled under 190 proof – Alcohol content as it comes off the still and before water is added – Some types require that whisky be distilled under 160 proof – If distilled multiple times, the highest proof is used for determining the classification. Aged not more than ____ years. TTB proposes to require that where a whiskey meets the standard for one of the types of whiskies it must be designated with that type name, instead of the general “whiskey.” TTB believes that consumers expect that the type designation will appear on the container when it applies. Previously, I think this only applied to whiskies that have been labelled ‘straight’ that were less than 4 years old and any whiskey less than 2 years old. I’m not aware of anyone putting straight whiskey into used barrels later in the aging process and counting that towards the age, but this seems logical to prevent this kind of nefarious behavior. The TTB rejected the proposal and distillers will continue to have the option of using the general class “whisky” or one of the type designations that applies. Presumably in an effort to combat this, the TTB has come out with new phrasing for its guidelines. The Alcohol and Tobacco Tax and Trade Bureau (TTB) today released the final document outlining changes to alcoholic beverage labeling regulations. Keep in mind that the regulations you cite are not really new, but a restatement of the regs. Distilled Spirits Labeling Alcohol Infused Whipped Cream Distilled Spirits Products - TTB requires a statement of composition on the label of products such as alcohol infused whipped cream that identifies for consumers the type of distilled spirit in the product, and as a result, the fact that the product is an alcohol beverage. Bulleit is a bit more subtle, and simply states their rye whiskey was produced by Bulleit Distilling Company in Lawrenceburg, Indiana. The statement “aged for less than 4 years” does not satisfy the requirements of 27 CFR 5.40 for an age statement, and it creates a misleading impression as to the age of the product. It is important however to realize that the regulations are of a whole and all must be met. TTB has not reviewed this label for type size, characters per inch or contrasting background. Can the age statement include minimum or maximum ages? ... or blending materials may not be added to any products designated as “bourbon whisky.” This has long been TTB’s policy, but now it will be in the rules explicitly. In the case of “light whiskyâ€, as defined in § 5.22((3), the State of distillation shall not appear in any manner on any label, when the appropriate TTB officer finds such State is associated by consumers with an American type whisky, except as a part of a name and address as set forth in paragraph (a) of this section Despite this, the labeling of some beers and some wines are regulated by the FDA. Both Jim Murray and I feel quite strongly about this. The terms apply to mixtures of Whiskeys of the same type. It is not accidental then that the Standards of Identity for bourbon (§5.22) is congruent with the aging statements you cite; specifically to be “bourbon” the spirit “…must be STORED at not more than 125° proof in charred new oak containers”. The beers and wines that are subject to FDA’s labeling jurisdiction […] Note: The TTB Public COLA Registry provides access to information about Certification/Exemption of Label/Bottle Approvals (COLA), which TTB issues on Form 5100.31. What information must be included in an age statement? In the 2018 Proposal, TTB proposed to require that, where a whisky meets the standard for one of the types of whiskies (e.g., bourbon), it must be designated with that type name, with an exception provided for Tennessee Whisky. The current list covers only a couple dozen cocktails and these are the ones that were popular when your father was young: cocktails like the grasshopper, apricot sour, mai tai, pink squirrel, and others. The TTB's goal is to ensure you're legally qualified to operate your distillery and that you'll do it safely and fairly. The following formats are acceptable: If percentages are listed, they must be based on the percentage of the finished product, on a proof gallon basis, contributed by each listed whisky, and the percentages listed must add up to 100%. I hope you enjoyed this trip through the TTB Standards Of Identity for Whiskey in Plain English. What are examples of acceptable formats for age statements? The TTB regulations at 27 CFR 5.40 (a) require an age statement on the label of any whisky that has not been aged for at least four years. You can label American whiskey with an age statement, "aged 32 nanoseconds," and comply. Those TTB regs say 'from grain' not 'from only grain'. The age of the whisky must be stated in hours, days, months, or years, as appropriate. What do you guys think about this? 5 Freelance writer, student of life. Kentucky bourbon. The front label must contain: (i) the brand name, (ii) whether it is bourbon, rye, corn, blended or light whiskey and whether it is a straight (i.e., class and type), and (iii) percent alcohol. Lighthearted conversation about news from the store. ( Log Out /  Enter your email address to follow this blog and receive notifications of new posts by email. The changes to TTB’s regulations that govern beer involved product label claims and the listing of alcohol content statement requirements. The TTB regulations at 27 CFR 5.40(a) require an age statement on the label of any whisky that has not been aged for at least four years. Blog TTB Beer Label Requirements: 8 Elements You Need on Craft Beer Labels The process of putting together a craft beer label can be as complex as brewing the beverage itself. Standards of identity for the several classes and types of distilled spirits set forth in this section shall be as follows (see also § 5.35, class and type): (a) Class 1; neutral spirits or alcohol. Alcohol by Volume Labelling – Standard 2.7.1 . Aged not less than ____ years. TTB previously required that the amount of alcohol in the bottle - say 80 proof (which equates to 40% alcohol) - had to be within 0.15% of the amount of alcohol stated on the label. See 27 CFR 5.40 and Chapter 8 of the Beverage Alcohol Manual (BAM) for additional information about optional age statements. Includes the definition of “Bourbon Whiskey” but additionally: Is required to be … Visit TTB's Formulation pages to learn more. This requirement applies to any whisky produced by mixing or blending if the youngest whisky in the mixture or blend has been aged for less than four years. Essentially, TTB is eliminating the requirement that whiskey must be aged, although whiskey that is not aged must be identified as either “unaged whiskey” or “white whiskey.” In addition, aged whiskey that has had its color stripped away by filtering also may be called “white whiskey.” TTB proposed to insert a chart for whiskey regulations. Just like misleading aging statements, it has become a common misrepresentation for distillers to incorrectly label a spirit as “bourbon”. Advocate for the Oxford Comma. This is where the TTB comes in. Follow us on Facebook. Chapter 5: Chapter 6: Chapter 7: Chapter 8: Chapter 9: Name and Address Standards of Fill Coloring/Flavoring/Blending Materials Statement of Age Containers, THE BEVERAGE ALCOHOL MANUAL (BAM) A Practical Guide, Basic Mandatory Labeling Information for DISTILLED SPIRITS Volume 2, Accessibility • Privacy Policy • No FEAR Act • Report Fraud Contact Webmaster • Site Feedback •. As an example, the label on George Dickel Rye very clearly states it is distilled in Lawrenceburg, Indiana, home to MGP. 0: administrative withdrawal: 00: administrative withdrawal: 000: administrative withdrawal: 100: straight whisky: 101: straight bourbon whisky: 102: straight rye whisky Can I simply label the product as having been “Aged for less than 4 years”? Follow up posts around the titillating subjects of whiskey label requirements, age statement regulations and Specialty Whiskeys are coming soon. The requirements for the declaration of alcohol by volume apply to foods generally but for the purposes of this guide the requirements will be expressed as for alcoholic beverages only. The spirit oxidizes during this aging period, and penetrates the wood, extracting many of the flavor compounds and caramelized wood sugars. And think beyond the kernel. The most interesting thing I noticed is that any product labelled as ‘whisk(e)y’ must have an age statement if it is less than 4 years old. If, perchance, your intended cocktail is on the list, TTB will be rather fierce abo… Let’s hope the agency will enforce section 5.22 as well. See 27 CFR 5.40(a)(4) for the requirements regarding disclosure of aging in reused barrels for certain products. The age may be understated, but the age may not be overstated. This is critical. Is an age statement required on a whisky label? Specially-Finished Whiskey Classification & Labeling Requirements According to the TTB I’ve been meaning to write something up about this for time, but I never get around to it. All other TTB-required information is already required to meet minimum type-size requirements. This requirement applies to any whisky produced by mixing or blending if the youngest whisky in the mixture or blend has been aged for less than four years. Provincial regulations may also have labelling requirements that apply when these products are sold within that province. TTB solicited comments on this proposal as a potentially restrictive change to the regulations, because in the current regulations, when a whisky meets the standard for a type of whisky, it is unclear whether the label must use that type designation or may use the general class “whisky” on the label. Want more bourbon? Change ), You are commenting using your Twitter account. In the current regulations, when a whisky meets the standard for a type of whisky, it is unclear whether the label must use that type designation or may use the general class “whisky” on the label. Personally I’m for anything that gives me the opportunity to be more confident of what I’m actually drinking. TTB proposes to require that where a whiskey meets the standard for one of the types of whiskies it must be designated with that type name, instead of the general “whiskey.” TTB believes that consumers expect that the type designation will appear on the container when it applies. ___% whisky aged __ years; __% whisky aged ___ years. The TTB proposes defining grain as including “cereal grains and the seeds of the pseudocereals amaranth, buckwheat and quinoa.” Change ). A major hurdle that most wine producers hit is the dreaded label design. This is TTB's page for the Beverage Alcohol Manual (BAM) for distilled spirits. Blog TTB Final Rule Breakdown: The New TTB Label Requirements for Alcohol Labels Over time, alcohol regulations are bound to change. Alcoholic beverages with prescribed standards in Division 2 of Part B of the FDR include whisky, rum, gin, brandy, liqueurs and spirituous … Under ____ years old. They aren’t perfect, and some don’t go far enough, but they are a good start at updating the regulations. Under the current regulations, whiskey must be made from grains, but the term “grain” is not defined. These changes are designed to streamline processes and provide extra flexibility for alcoholic products. Currently, TTB allows the term “Tennessee Whisky” to appear on labels, even if the product meets a more specific standard of identity, such as for bourbon whisky.” Background- Currently a distiller can bottle a spirit that meets all the legal requirements for bourbon yet they can chose not to put the word “bourbon” on the label. The responsible industry member must continue to ensure that the mandatory information on the actual labels is displayed in the correct type size, number of characters per inch, and on a contrasting background in accordance with the TTB labeling regulations, 27 CFR parts 4, 5, 7, and 16, as applicable. Thanks to Chuck Cowdery for the heads up on his blog. That’s why it’s critical to keep up to date with new changes to alcohol labeling laws, such as the latest final rule from the Alcohol and Tobacco Tax and Trade Bureau (TTB) . Laws, Regulations, and Public Guidance Laws and regulations set out the requirements for alcohol beverage labeling. Having been stored for a time in “used oak”, you no longer have a bourbon, but at best might label the spirit correctly as a “whiskey made from bourbon mash”. Wheat whiskey, malt whiskey, and rye malt whiskey have the same distillation requirements as bourbon and rye. The requirements for standard drink labelling apply to beverages or food capable of being consumed as a beverage, where the alcohol by volume is more than 0.5%. See 27 CFR 5.40(e)(2) for rules applying to age, maturity, and similar representations. They may not omit label statements that are required, but they can do it if no one enforces the requirement. Something that has been somewhat more nebulous is the correct stating of age in whiskey. TTB has not reviewed this label for type size, characters per inch or contrasting background. Wine Labeling. Whisky Labeling. The beers and wines that are subject to FDA’s labeling jurisdiction […] Some subtypes of whiskey have more stringent requirements, but simple 'whiskey', not 'wheat', nor 'straight', is pretty wide open. Additionally, the TTB regularly exempts non-traditional ingredients commonly used by brewers from triggering TTB formula approval requirements, such as certain fruits and spices. If a bourbon moves from charred new oak, it had better be for bottling – further storage for finishing in say a used sherry and you can’t call it a bourbon. It’s nice to see such attention and detail to age, particularly in re bourbon,which you correctly note must be “aged” in “charred new oak”. This week, the TTB announced a new list of proposed whiskey classifications and requirements. The Federal Alcohol Administration Act (“FAA”) regulates the interstate and foreign commerce of wine, spirits, and malt beverages and bestows general authority to oversee these products to the TTB. ON THE LABEL Under 27 CFR §5.32, the label of each bottle of whiskey must contain certain information. CoverGoverning Laws and RegulationsTable of Contents (For updated guidance on Ouzo and Aquavit see TTB G 2018-8), Type Size and Legibility Requirements for Health Warning Statement, Class and Type Designation (For updated guidance on Ouzo and Aquavit see TTB G 2018-8). The regulations at 27 CFR 5.40(a)(5) provide that optional age statements must appear in the same form as required statements. You’d think this is pretty straight forward, but there is a lot of creative wording out there. The TTB regulations have long been in need of an update to cover newer whiskey styles that have emerged in the past decade. Blended whiskey must contain at least 20% straight whiskey or a blend of straight whiskeys. What are examples of age statements that are not acceptable? The Alcohol and Tobacco Tax and Trade Bureau (TTB) today published a final rule to address certain proposals included in Notice 176, Modernization of the Labeling and Advertising Regulation. Distilled no higher than 160° proof (80% ABV). The TTB regulations at 27 CFR 5.11 define the term “age” to mean the period during which, after distillation and before bottling, distilled spirits have been stored in oak containers. Key Wine Labeling Topics. The NAS on Scotch and Irish are acceptable, but the products have a minimum age period that American regulation does not impose. Specially-Finished Whiskey is a growing category, I can testify to this by the increase of such products to cross my desk in the last couple years. It also adds specific examples at the bottom of how to label blended whiskies. In general, the new TTB label requirements aim to modernize labeling and advertising regulations. This requirement applies to any whisky produced by mixing or blending if the youngest whisky in the mixture or blend has been aged for less than four years. Put into a charred new oak container no higher than 125° proof (62.5% ABV). The Federal Alcohol Administration Act (“FAA”) regulates the interstate and foreign commerce of wine, spirits, and malt beverages and bestows general authority to oversee these products to the TTB. A Templeton Rye whiskey label. First off, TTB keeps a quaint old list of “recognized cocktails” here. They also define the aging statement as referring to time in ‘new oak containers’ for any ‘straight’ product. A minimum age (such as “aged at least __ years”) is acceptable, but a maximum age (such as “aged for less than ___ years”) is not acceptable. Is an age statement required on a whisky label? As for goosing abv, submit formulas and see what gets approved. The TTB regulations at 27 CFR 5.40(a) require an age statement on the label of any whisky that has not been aged for at least four years. ( Log Out /  Do note that 5.22 does not distinguish “aging” from “finishing”, but comingles both these terms as “storage”. If the whisky contains no neutral spirits, the age must be stated either as the age of the youngest whisky, or as a statement that includes the age of each whisky in the mixture or blend, and the percentage of that whisky in the mixture or blend. To clarify, this means that the brand label may be on any side of distilled spirits bottles, but must show the brand name, class and type designation, and alcohol content within the same field of vision. Aged less than ____ years. Whisky Labeling. Although information about TTB requirements is readily available, it can sometimes feel like the regulations are written in a foreign language. Wine, which includes cider and mead, must be properly labeled before it can be sold in the U.S. marketplace.This guidance will help you understand TTB’s requirements for wine labels. As stated in the new guidelines, "The TTB regulations at 27 CFR 5.40(a) require an age statement on the label of any whisky that has not been aged for at least four years. The same can easily apply to this. Thus a bourbon must only be stored in “charred new oak”, period, regardless of what you want to call it. TTB US Wine Label Requirements We think we have a name for our winery and now we're looking at the regulations for the wine label. Notice No. TTB will not approve labels with the following age statements, because they list a maximum age instead of a minimum age, and thus may mislead consumers as to the age of the product: We’re looking at you Templeton Rye. Aged _____ years. I am bottling a straight whisky that consists of one straight whisky that has been aged for 3 years and another straight whisky that has been aged for 2 years. TTB proposed to insert a chart for whiskey regulations. _____ years old. What is the “age” of a whisky? TTB is amending existing § 5.40(a)(1) regarding statements of age for whisky that does not contain neutral spirits to provide that multiple barrels may be used and to provide that the label may optionally include information about the types of oak containers used. Do the format rules for mandatory age statements also apply to optional age statements? Last year, the American Craft Spirits Association (ACSA) spearheaded a six-month effort to gather members’ comments on the proposed rulemaking related to modernizing labeling and advertising requirements … Attorneys for Label Approvals in Boise We Work Directly with Business Owners & Designers. No. Customers might judge a bottle by its label, which is why distillers, brewers, and winemakers invest a lot of time and money into designing their labels. The resulting final rule documents several regulatory changes … TTB audits distilleries and tests for the accuracy of alcoholic content. “Neutral spirits” or “alcohol” are distilled spirits produced from any material at or above 190° proof, and, if bottled, bottled at not less than 80° proof. If the whisky contains neutral spirits, see 27 CFR 5.40(a)(2) for rules that apply to statements of age and percentage. Over ____ years old. I suppose this is to prevent counting any aging in a barrel finished process. How should age be stated if the whisky consists of a mixture or blend of whiskies with different ages? Fill in your details below or click an icon to log in: You are commenting using your WordPress.com account. In Notice No. P.S. The TTB label maintains three lists of formula approval requirements for different beverages, one for wine, one for distilled spirits, and a final one for malt beverages. Louisville. The TTB received opposition by many who stated that this change would require many current labels to change. Even the back of the production report says 'grain and grain products'. ( Log Out /  Despite this, the labeling of some beers and some wines are regulated by the FDA. In the 2018 Proposal, TTB proposed to require that, where a whisky meets the standard for one of the types of whiskies (e.g., bourbon), it must be designated with that type name, with an exception provided for Tennessee Whisky. The recent TTB proposal to modernize spirits regulations added a host of new definitions for terms that are widely used but not defined in the regulations, including “cask strength,” “white whiskey” and “oak barrel.” Despite the voluminous nature of the TTB proposal, though, there are still a number of widely used terms that are not defined in the regulations, including the following: Mash must contain at least 51% corn (Bourbon Whiskey), rye (Rye Whiskey), wheat (Wheat Whiskey), malted barley (Malt Whiskey) or malted rye grain (Rye Malt Whiskey). The labeling modernization ruling, called “Notice 176: Modernization of the Labeling and Advertising Regulations” comes after a year of public comment, starting in late 2018, regarding proposed changes to existing regulations. Whisky produced in the U.S. at not exceeding 80% alcohol by volume (160 proof) from a fermented mash of not less than 51 percent wheat and stored in used oak containers WHISKY … Down to the hour if applicable. The TTB, or Alcohol and Tobacco Tax and Trade Bureau, is the government agency responsible for alcohol product labeling, and that's where regulation or reform would need to begin. references and requirements in Standard 2.7.4 – Wine and Wine Products and Standard 2.7.5 – Spirits. Change ), You are commenting using your Facebook account. 176, TTB proposed to add in parts 4, 5, and 7 a definition of “Certificate of Label Approval.” Under the proposal, the certificate of label approval is defined as a certificate issued on TTB Form 5100.31 that authorizes the bottling of wine, distilled spirits, and malt beverages, or the removal of bottl… Standards of identity for the several classes and types of distilled spirits set forth in this section shall be as follows (see also § 5.35, class and type): (a) Class 1; neutral spirits or alcohol. Getting Started with Wine Labeling TTB has not reviewed this label for type size, characters per inch or contrasting background. The core aging requirement that defines a whiskey as straight is if the distillate has spent at least two years stored in charred new oak barrels, except corn whiskey which must use uncharred or used oak barrels. This list does not do an especially good job of recognizing that cocktails come and go like fashion, and there are many modifications upon even the most enduring themes. It contains links to individual sections pertaining to Mandatory Label Information, Type Size and Legibility Requirements, Type Size and Legibility Requirements for Health Warning Statement, Class and … The BATF, or the Bureau of Alcohol, Tobacco and Firearms, now is called Alcohol and Tobacco Tax and Trade Bureau and goes by the shortened, TTB. Aged at least ____ years. It has to be distilled from a mashbill of at least 51% corn, it must be distilled to no more than 80% ABV, it has to be bottled at a minimum of 40% ABV, and it … This article is intended to take some mystery out of this… Whisky Labeling. “Neutral spirits” or “alcohol” are distilled spirits produced from any material at or above 190° proof, and, if bottled, bottled at not less than 80° proof. Per inch or contrasting background they can do it if no one enforces the requirement need of an to! A common misrepresentation for distillers to incorrectly label a spirit as “ storage ” about TTB requirements is readily,. Statements, it has become a common misrepresentation for distillers to incorrectly a. Notifications of new posts by email today released the final document outlining changes alcoholic! ) today released the final document outlining changes to alcoholic beverage labeling email address to follow this blog receive! 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