tag:blogger.com,1999:blog-9082156144028140004.post2031797417820943015..comments2024-03-13T04:04:32.568-07:00Comments on Sku's Recent Eats: Why isn't the TTB Enforcing the State of Distillation Disclosure Rule?skuhttp://www.blogger.com/profile/00487419662314518931noreply@blogger.comBlogger12125tag:blogger.com,1999:blog-9082156144028140004.post-63879998831194272432015-01-09T08:45:51.765-08:002015-01-09T08:45:51.765-08:00Interesting theory Anon. I don't think I'...Interesting theory Anon. I don't think I've heard that interpretation yet, but it is consistent with the regs.skuhttps://www.blogger.com/profile/00487419662314518931noreply@blogger.comtag:blogger.com,1999:blog-9082156144028140004.post-26015485580595513522015-01-09T00:28:52.673-08:002015-01-09T00:28:52.673-08:00Here’s my two cents. 5.36(d) is referring to an ad...Here’s my two cents. 5.36(d) is referring to an address on the “brand label,” not the back label. (See 5.11 “Meaning of terms” for brand label.) Basically, the brand label is the front label meant for retail, consumer show. If the producers put their address on that label, then they must also include the state of distillation, if different, per 5.36(d) to avoid mischaracterization or confusion. Most producers don’t dabble with address statements on the brand label but, rather, exclusively use the back label for the address statement and “bottled/produced by.” Or, maybe, the TTB is just not enforcing the reg...Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-9082156144028140004.post-61194017393988145542012-09-09T17:33:00.670-07:002012-09-09T17:33:00.670-07:00Drink Spirits, thanks for the comment. They actua...Drink Spirits, thanks for the comment. They actually have a NOM type system for whisky; it's called the Distilled Spirits Plan (DSP) Number but it's only required on Bottled in Bond whiskies. skuhttps://www.blogger.com/profile/00487419662314518931noreply@blogger.comtag:blogger.com,1999:blog-9082156144028140004.post-59022041769088383632012-09-09T11:33:54.659-07:002012-09-09T11:33:54.659-07:00The TTB is famous for inconsistent rules and enfor...The TTB is famous for inconsistent rules and enforcement. I totally agree how important point of origin is on whiskey, especially with so much Merchant whiskey coming into the market from small distillers who are bottling and labeling it as their own.<br /><br />I really respect what Bull Run Distillery did with theirs where they CLEARLY indicated that they did not distill their Temperance Trader Straight Bourbon <br /><br />http://www.drinkspirits.com/bourbon/temperance-trader-straight-bourbon-whiskey/<br /><br />I'd love it if the TTB created a NOM system like they do in tequila so you can look up the source of everything.Drink Spiritshttps://www.blogger.com/profile/18088962058098058793noreply@blogger.comtag:blogger.com,1999:blog-9082156144028140004.post-55547548122609026152012-09-05T16:40:21.969-07:002012-09-05T16:40:21.969-07:00ilium55 and Chuck, I think most of the big produce...ilium55 and Chuck, I think most of the big producers are complying. It's some of the smaller players that seem to be lacking the state of distillation.skuhttps://www.blogger.com/profile/00487419662314518931noreply@blogger.comtag:blogger.com,1999:blog-9082156144028140004.post-85480751238207116052012-09-05T16:38:41.279-07:002012-09-05T16:38:41.279-07:00Looking at a bottle of Willett Rye on my shelf it ...Looking at a bottle of Willett Rye on my shelf it states that it was distilled in Indiana (LDI I assume) and bottled in Bardstown. So someone is complying at least. ilium55noreply@blogger.comtag:blogger.com,1999:blog-9082156144028140004.post-70798096447509647102012-09-05T13:01:20.490-07:002012-09-05T13:01:20.490-07:00I don't want to name names because in some cas...I don't want to name names because in some cases I believe the bottlers aren't at fault and are just doing what they are told, but there are a number of distilleries/bottlers that are using LDI or Kentucky juice that don't have the state of distillation on the label or the address.skunoreply@blogger.comtag:blogger.com,1999:blog-9082156144028140004.post-14648828777954086052012-09-05T12:32:30.964-07:002012-09-05T12:32:30.964-07:00Fair enough, but subsection (d) only applies "...Fair enough, but subsection (d) only applies "if the whisky is not distilled in the State given in the address on the brand label." Realizing that caveat, who do you think is in violation? Sazerac wrt Bowman? But Bowman is distilled (redistilled) in Virginia. Otherwise just about everybody else distills in KY and has a KY address, or distills in TN and has a TN address, so who's not in compliance?Chuck Cowderyhttps://www.blogger.com/profile/12191121480961526039noreply@blogger.comtag:blogger.com,1999:blog-9082156144028140004.post-63499105216776489512012-09-04T16:08:41.646-07:002012-09-04T16:08:41.646-07:00Thanks for your response Chuck. Is that your inte...Thanks for your response Chuck. Is that your interpretation or the TTB's? The problem I have with it is that the portion you quote is that it is from subsection (a)(6) which deals with the statement "bottled by" on all distilled spirits as part of sub (a). <br /><br />The state of distillation requirement is in subsection (d) which appears to set up a wholly separate requirement for listing the state of distillation, specifically applying to whiskeys.skunoreply@blogger.comtag:blogger.com,1999:blog-9082156144028140004.post-26323497095579922092012-09-04T16:02:50.979-07:002012-09-04T16:02:50.979-07:00The answer (and the out for producers) is "(6...The answer (and the out for producers) is "(6) The label may state the address of the proprietor’s principal place of business in lieu of the place where the bottling, distilling or rectification operation occurred, if the address where the operation occurred is indicated by printing, coding, or other markings, on the label or on the bottle." Chuck Cowderyhttps://www.blogger.com/profile/12191121480961526039noreply@blogger.comtag:blogger.com,1999:blog-9082156144028140004.post-64159630520192376792012-09-04T15:04:31.641-07:002012-09-04T15:04:31.641-07:00The regulation I'm referring to, for some reas...The regulation I'm referring to, for some reason, only applies to whiskey. Brandy can get away with a "bottled by" statement and still be consistent with the regs.skunoreply@blogger.comtag:blogger.com,1999:blog-9082156144028140004.post-89385826175226018932012-09-04T14:54:24.594-07:002012-09-04T14:54:24.594-07:00This also seems not to be done with domestic brand...This also seems not to be done with domestic brandy. Look on a bottle of Christian Brothers or Paul Masson -- the address is likely Bardstown Ky. When I went to the Barton Distillery where one for the other is bottled ( can't remember which) they said the Brandy was distilled in California, sent to them in railroad tankers, and aged and bottled in Kentucky.ilium55noreply@blogger.com