Monday, July 21, 2014

Brandy Law

I've spent a lot of time (and I mean a silly amount of time) reviewing and discussing the TTB's whiskey regulations, and I've also posted about the regional requirements for Cognac and Armagnac, but I've never delved into the American regulations covering brandy, which include some interesting stuff, so here's a summary.

Brandy is defined by American regulations as "an alcoholic distillate from the fermented juice, mash, or wine of fruit, or from the residue thereof."  Like whiskey, it must be produced at less than 190 proof and bottled at a minimum of 80 proof. 27 CFR § 5.22 (d).

If the brandy is made from grapes it is "grape brandy" or just "brandy." If it's an aged brandy that's aged in oak for less than two years, it has to be labeled "immature." brandy (I'd sort of like to see that one apply to whiskey). 27 CFR § 5.22 (d)(1).

A brandy made from one type of fruit other than grapes must be labeled with the name of the fruit (e.g. "peach brandy"), except that apple brandy can be called "applejack."  If a fruit brandy is made with more than one type of fruit, then it's "fruit brandy," but must also include "a truthful and adequate statement of composition."  27 CFR § 5.22 (d)(1).

Those are the basics, but there are lots of other brandy types that are defined, including dried fruit brandy, lees brandy, pomace brandy and many more, but those are fairly obscure categories. My favorite is "substandard brandy" which includes "any brandy which has been distilled from unsound, moldy, diseased, or decomposed juice, mash, wine, lees, pomace, or residue."  Yum!

While there are lots of different brandies, the regulations for it are much looser than whiskey.  For instance, brandy can include caramel coloring and treatment with oak chips (a common additive) without disclosing it on the label. 27 CFR § 5.39.

That's a starter for you.  I will delve into the regulations in more detail in the future.


Florin said...

I could look it up but it's easier to ask you: do these regulations apply to imported brandy as well? This is relevant, since most of the brandies on the market are imported.

sku said...

Florin, it appears that some do and some don't. Cognac and Pisco have their own TTB definitions which define them as any brandy that is proper under the laws of their country (France for Cognac, Chile or Peru for Pisco). Interestingly, there is no similar regulation covering Armagnac, Brandy de Jerez or any other barndy, so those would presumably have to comply with the American regulations.

Andrew said...

I'm waiting for Bruichladdich to come out with a substandard brandy, carefully distilled in Ugly Betty using only the finest Bordeaux grapes, slow-molded from a twelve day, unrefridgerated sea voyage from Chateau Petrus. Call it, Bruichladdich Noble Rot.