Craft is Crap pt. 2

In my last rant, I tackled the overuse of words like “Handcrafted” and “Artisanal”. In this one, we’ll go the other route and talk about what words you can and cannot use on your label. This all regards labelling in the U.S. and the TTB’s (Trade & Tax Bureau) Standards of Identity.After prohibition, new standards of identity were determined to help regulate labeling and to protect the consumer from being sold fraudulent products. In a world where alcohol served more of a utilitarian purpose, this worked just fine. If you liked Bourbon, anything labelled as such was what you wanted. Rum? Scotch? Brandy? Same story. These standards however haven’t really been expanded on much since repeal came some 83 years ago. Think about how much everything else in the world has changed in the past 80 years. Go talk to your grandparents if it’s hard to fathom. Now we’re in the midst of a spiritual revolution (yes, I said it.) New styles of spirits are being created all the time. “Whiskey” is the overarching category for things like Bourbon, Irish, Scotch, Blends, etc. There are a handful of them but none of them really tell you much about what to expect flavor wise. They don’t have to tell you what kind of grain (Except in Bourbon or Single Malt Scotch), what percentages of grain are used, how it was distilled (Pot still vs. Column Still). Cooperage type is specified in only a couple types (Again Bourbon and also Corn whiskey.) With the Craft distilling movement though we are seeing whiskey produced from all kinds of grains and aged in all kinds of barrels. The TTB, from what I’ve seen, is doing their best to allow small distillers to provide this information on their label, which is great, the problem however is when those same allowances or loopholes go the opposite way.Our Dear Johnny whiskey was born out of a love for Bourbon, smoky Islay Scotch and Mezcal along with a desire to see more creativity in the craft distilling world. From the beginning I wanted to incorporate apples in some form since they pair so well with Bourbon. The question was how. If the apples were fermented, then it would no longer be a whiskey but a hybrid of whiskey and apple brandy. I also wanted to incorporate the smoky flavors found in Islay and Mezcal. Early experiments with smoked grain left me disappointed. Eventually I had the idea to smoke apples, unfermented and re-distill our whiskey with them in the pot. The results were fantastic and you can read more about that process in an older post. The trouble with this is the TTB didn’t know what to make of it. From their point of view, it couldn’t be a regular whiskey since something was added to it for flavor. The hypocrisy of this though is that Tennessee whiskey, by its very definition, has something added for flavor. The Lincoln County process (filtering through sugar maple charcoal after distillation) adds a clear sweet & smoky flavor to a whiskey that would otherwise be Bourbon. The trouble though is the people working in Labelling & Formulas aren’t there to create the rules, just enforce them as they stand. What this meant for us is that our whiskey was then considered a “Flavored Whiskey”. Now, when most people think of flavored whiskey, they think of the abominations that contain very little whiskey and obscene amounts of artificial flavoring and sugar. This was not Dear Johnny.Without knowing any other options, we went forward with the “flavored whiskey” misnomer thinking that people would look into it further or give it a chance before judging. Fast forward to the end of our first year on the market and the most common feedback I get from liquor stores and unfamiliar customers? They assumed it was similar to other sugary, apple flavored whiskies. I often relate the story to people about how Crown Apple was released about the same time I had finalized the process for Dear Johnny. Knowing the difficulty this would cause, but having a unique product I believed in, we soldiered on and released it. Fast forward to 1 year on the market and those regulations pushed upon our label are clearly hurting us and have us looking at a rebrand to make it clearer for people to understand it’s not a sugar bomb.So, while well intended, the current regulations allow little room to explain more clearly what you have done to create your product. This works in favor of the larger brands who have tightly guarded secrets regarding additives and formula development. For a small producer like us though, producing things in a much more organic manner, this can be a killer. The list could go on and on but I think I’ve made my point. It’s important to be educated about what you’re purchasing.