• Distilled Spirit Specialty

  Specialty Distilled Spirits – Labeling Terminology

  Posted by sorghumrunner on July 7, 2014 at 12:11 am

  So I’m getting ready to submit a COLA for our Sorghum Rum. Which we can’t call a rum (though others have…), but will call Sorghum Cane Spirit. So I’m trying to figure out, on the back label text, can we use the word Rum at all? As in, ‘substitute for your favoritue rum’… I’m guessing that’s probably gonna raise flags, but in my reviewing the BAM and some looking around in the CFR, I haven’t seen an explicit no-no.

  conejo148 replied 10 years, 5 months ago 3 Members · 4 Replies
• 4 Replies

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  dhdunbar

  Member

  July 10, 2014 at 6:12 am

  I consult. But I tell people I won’t consult on labels. Ask me about Sorgjum Ru and I’m going to tell you if it ain’t cane sugar – beets sugar doesn’t count, sorghum doesn’t count – and then your going to find that TTB approved a rum that wasn’t cane sugar. Or is a rum that is aged. Or is a whiskey that isn’t aged. My GUESS is that TTB will not object to the “substitute for your favorite rum” statement. You are not disparaging a competitors product. You are plainly saying its not rum. Any statement about being a substitute for something else is going to be – or should be – taken as puffery. So submit two COLA’s, one with the substitute statement and one without. See what happens. I don’t think you are scamming the system. If you knew it wasn’t correct, that would be different. But you don’t know and the only way to get TTB to comment these days is to submit a label for approval and see what they say.

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  dhdunbar

  Member

  July 11, 2014 at 3:05 am

  Meant to say gin that was aged. I was late.

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  sorghumrunner

  Member

  July 14, 2014 at 2:02 pm

  Oh good, I was trying to figure out how to not age a dark rum!

  Thanks for the input. I think what I’ll be trying is submitting a couple label text variations, sorry everyone in line behind me!

  And of course, one with Sorghum Rum, just to see if they are paying attention…

  Meant to say gin that was aged. I was late.

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  conejo148

  Member

  June 26, 2015 at 2:17 pm

  Old post, but did you ever get an answer? If you didn’t know, someone in Indiana had a label approved for unaged and aged products. Here’s the link for one. Search the public COLA for “sorgrhum.” I think the brand is no longer available.

  https://www.ttbonline.gov/colasonline/viewColaDetails.do?action=publicDisplaySearchBasic&ttbid=11314001000147

  BTW, I used to work in Pittsboro for HydroTube from 1998-2000. Kind of miss the place.

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