Monday, August 24, 2015

Whiskey Law: The Age Statement

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.


My Annoying Opinions said...

This is your funniest post yet!

WTK said...

Um, looking at my bottle of Corbin Cash rye whiskey, batch 1, it states aged "-4 years". Bottle is from 2014, must be before the Fed 'crackdown'.

sku said...

Yeah, it's only very recently that they seem to be drawing attention to age statements. Lots are still out there that violate the rules, and even some that still get approval. For instance, Four Roses Limited Edition Small Batch lists ages of different whiskeys in the blend but not percentages.

Curt said...

I think most people who have moderate experience drinking American whiskey can tell whether the whiskey has been aged more or less than 4 yrs in a barrel. And if you can't tell, I'm not sure why you would care. My go to bourbon is Henry McKenna Bottled in Bond and I appreciate knowing that it has been aged ten yrs, and it tastes like it. Great value! However, my favorite rye whiskey is High West Rendezvous Rye and it says nothing about age on the label only that it is a blend. And I can understand why HW would forego listing the age and % of each of the whiskey's used in the blending process so as to give them more options in the future under the same label. But if the quality of the blend starts to wane, I'll buy something else.

Patrick said...

If you check out their website, you can see what the component whiskies are that go into Rendezvous ( in all the juicy details. What it does NOT do, however, is list the percentages. It says on the back label that you can search by batch number to know more about the blend, as it could switch a tiny bit from batch to batch I assume, but I could not find a place on their site to do so.

sku said...

High West will list the ages on the website (which is not subject to the same restrictions as the label), and they've recently changed some labels to comply with this rule, but they consider their percentages proprietary and do not publish them anywhere.