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Label for Bourbon Whiskey
I submitted a cola for a boubon whiskey and got it back stating I needed to attach an approved formula. For bourbon whiskey??? Not according to their own formula tool online. Anyone else run into this problem?
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6 Replies
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unless something on your label suggested it required a formula, that is, took it outside of the standard. or you didn’t classify it correctly. or who knows? first thing you do in this situation is call them. mistakes also happen, and they usually try to correct them.
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I’ve called, waiting for a reply call. Its possible that its because the word whiskey was missing. Doh!
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I would be interested in knowing the outcome.
When I called TTB a year or so ago and asked if the formula requirements were correct, that TTB required a formula for whiskey, but not bourbon or whiskey distill led from malt mash, etc, I was told that was correct, “because of all the white whiskey out there.” I discreetly refrained from further comment on the grounds that I did not need a swarm of white whiskey hornets swarming around my head demanding to know why I’d stirred the nest up further.
I think the request for a formula was probably made in error, but the general pushing of envelopes on standards of identity by persons in the craft movement is going to become a matter of contention at some time. For example, as you probably know, the regulations require statements of age on any product aged for less than four years. Want to bet money that this is often ignored? Such practices could lead to TTB requiring, for any product lacking an age statement, a formula for pre-COLA evaluation that includes a statement of the time the product spends in new charred oak.
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The craft distillery industry can head some of the aging issue off very simply: state the aging to the best of ones ability. If you age in a range, state that. If never more than a certain time, state that. We went so far in our single barrel baby bourbon to print up two labels, so that if it is aged 3 months, we state that, or 4 months, etc. Truth in advertising from the craft distiller will help TTB and our consumers.
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I am about to submit my first set of 3 labels/formulas for approval. I am concerned that I may not have everything correct and that I will wait 40 days, and then have to make a bunch of changes. Is there anyone that feels confident in their knowledge/experience that would be willing to take and hour or so and review my labels before I submit them? I would be willing to compensate for this as well. I will be submitting labels for un-aged/white rye and rye aged for less than 1 year.
Cheers!
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There is Whiskey and then there’s Bourbon. Do you have on the label what it is distilled from? I would be happy to take a look at your label files. I also have a good contact at TTB that I can call directly.
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