Recently, the TTB seems to be cracking down on improper age statements on whiskey labels, so I thought I would provide this brief primer on age statements on American labels.
- There are no minimum ages for American whiskeys. However, to be labeled "straight," a whiskey must be at least two years old. 27 CFR §5.22(b)(1)(iii).
- The age of a whiskey means the period for which it was stored in oak or, where new charred oak is required (as in bourbon, rye, etc.), the period for which it was stored in new charred oak. So if a bourbon is finished in a wine cask, the finishing period cannot be part of the listed age (though the label can state separately how long it was aged in the finishing cask). Similarly, if a whiskey is transferred to steel tanks, the period in those tanks cannot be included in the listed age. 27 CFR §5.11
- An age statement is required to be listed on the label if the whiskey is younger than four years old. 27 CFR §5.40(a).
- The age statement on the label must be the age of the youngest whiskey included in the bottle and the age may be understated but not overstated. 27 CFR §5.40(a)(1), 5.40(e)(1).
- A minimum age statement ("at least 2 years old") is acceptable but maximum age statements ("aged less than 2 years old") are prohibited. Distilled Spirits FAQ, S11. This is one the TTB seems to be cracking down on.
- If a label lists the age of more than one whiskey contained in a bottle, it must list the percentage of each such whiskey in the bottle. (TTB Beverage Alcohol Manual, Chapter 8). This is to prevent a label from saying the whiskey is a blend of 2 year old and 17 year old bourbon when there is only a drop of 17 year old whiskey in it. This has not been enforced in the past, but there are some signs that the TTB has become more strict about it.