All Tennessee Whiskies are Bourbon? What about Jack Daniel’s?

“All Tennessee Whiskies are Bourbons”.   I saw this statement made the other day in one of the Facebook Bourbon info groups and would like to address this.  When a US produced spirit is labeled Whiskey, it means it meets the standards for federal code class type 140 – Whisky. Note the TTB always uses Whisky but Whisky/Whiskey spellings are interchangeable.  Class type 140 is a very broad whiskey definition. Requirements for Class type 140 are the spirit must be made from grain, distilled below 190 proof, and bottled at not less than 80 proof. Following federal codes for whisky, it must have contact with an oak container, be it new or used, charred or not.  Up to 2.5 % coloring/flavoring/blending materials may be added without disclosure. If a spirit is produced completely in one state then that producer may put the state in front of the product type on the label. Therefore, a distillery in TN could produce TN Whiskey that was distilled to 189 proof, aged in used barrels and have 2.5% flavorings added to it.  This would be TN Whiskey, but it is a far cry from Bourbon. So, the statement of “All Tennessee Whiskies are Bourbons” is false.

Confusing matters, somewhat, is the fact Tennessee passed its own law defining TN Whiskey in 2013.  While TN law does not override federal code, it does establish their own standard. It mostly follows the federal code definition of Bourbon but adds “Filtered through maple charcoal prior to aging” as a step.  It also gives a legally dubious exception for this step that only applies to one distillery in TN. However, nothing in the TN code prevents the use of 2.5% flavorings. So even under this TN law, one could make TN whiskey that has 2.5% flavorings that would still not meet the legal definition of Bourbon.

This brings us to the never ending online debate of “Is Jack Daniels a Bourbon?”  Jack Daniels is labeled as TN Whiskey. It meets all the enacted TN whiskey laws and JD claims they add no flavorings or coloring.  The step of filtering through maple charcoal prior to aging is referred to as the Lincoln County process. Those who say JD is not a bourbon usually point to the Lincoln County process as the step that prevents it as being such.  The other camp points out nothing in the federal code prevents Bourbon from employing charcoal filtering. In fact, many bourbons state on the label that they are charcoal filtered. In general, charcoal filtering removes compounds and does not them add them.  I fall into the camp that since nothing is being added JD could be called Bourbon if they so elected. I rarely see asked but I have often pondered if JD could be called Straight Bourbon? It’s aged 4 years so it meets the age requirement but then it gets a little more complicated.

There is a section in federal code that discusses when formulas are needed for spirits that have been changed through a process that alters their character, composition or class type.  Straight Bourbon never requires a formula. 27 CFR 5.27 (c) any filtering or stabilizing process which results in a product which does not possess the taste, aroma, and characteristics generally attributed to that class or type of distilled spirits; and, in the case of straight whisky, results in the removal of more than 15 percent of the fixed acids, volatile acids, esters, soluble solids, or higher alcohols, or more than 25 percent of the soluble color.  Does the Lincoln County process, which is a filtering process used by JD, remove more than 15% of these?  If the answer is yes, then JD is not Straight Bourbon. Since JD elects not to call their whiskey Bourbon or Straight Bourbon we may never know the answer to this.

Update – Jeff Selgren said I should credit him as the person that stated incorrectly that “All Tennessee Whiskey is Bourbon”, so Jeff so referenced.  

OWA/W12 – How long does it take whiskies to marry together?

Have you ever made a batch of the Old Weller Antique/Weller 12 mix?  If so, how long does it need in the bottle to marry together for the best results?  Is it instant? Do you wonder about these things or is it just the whiskey geek in me?  I was of the opinion that if you take 2 different bourbons, put them in a bottle and give them a good shake, they would be as mixed together as possible.  While visiting various distilleries and listening to folks much more knowledgeable I kept hearing it takes time for whiskies to come together, or marry.

If you noticed I called it OWA/W12 mix and not the much more common social media term of “Poor Man’s Pappy.”  This is because I know the gentleman that devised this mix, Gary Gillman. Gary was actively involved in the forums of StraightBourbon.com and was routinely vatting different whiskeys.  So much so that we referred to his process as Gillmanization. When Weller Centennial was discontinued around 2008, Gary developed this mix to be a replacement for Centennial and not as a substitute for Pappy.  I also try to refrain from using the word blend and instead use vatting, marrying or mix. Blended US whiskies with their use of GNS, aka Vodka, as well as coloring/flavorings have a poor, deservedly so, reputation.  

I decided to put this to a test.  This was done a few years back before I started blogging.  I mixed up one batch using the typical 60% OWA and 40% W12 which I let marry in a bottle for 30 days.  The other batch used the same ratio but was mixed together with a good bottle shake right before the test.  I used the same blind triangle test as I did in the “Did my bourbon change in the bottle?” tests. Testers would taste 3 samples; 2 from the bottle that was freshly mixed and 1 from the bottle married for 30 days, or vice versa.  Either way, one of the 3 samples is the odd sample and if change is perceptible enough then it would be identifiable. I did not ask which tasted better, I only asked if they could identify the odd sample.  We had about 6 people at this whiskey get together and they all tried this test. A few repeated the test with new blind samples so that I had a total of 10 tests.  9 out 10 testers identified the odd sample. Beyond that most also correctly identified which was the aged for 30-day sample. One tester did this twice by just nosing samples.  My conclusion is that the time in the bottle the whiskey marries together will noticeably change the taste.

I’m not sure what the optimal amount of time involved would be to properly marry.  Is it 2 weeks or 2 months? So I asked an industry expert, Nancy L. Fraley, for her opinion.   Nancy has worked with many distilleries on blending and whiskey maturation. While I asked her about this OWA/W12 mix, should gave me a much more elaborate answer ranging from a producer production scale to relating that to our small consumer project.  Here is Nancy’s full answer:

“From a production standpoint, I was trained and have seen from experience that after barrels are harvested and dumped, the longer they are allowed to marry in stainless steel tanks (and always of a passivated grade of either 316L or 2205), the better the mixture will be. Whenever I marry casks, doing a minimum of 1 month, although 3 to 6 months or longer in stainless is what I always prefer whenever possible, assuming the production schedule allows that and the tank space is available.

Depending upon the product I’m working on, if I can allow a blend to marry in exhausted casks rather than using a passivated grade of stainless steel, that is even better because it is an “organic” oxidation vessel, with gentle ingress and egress of oxygen, which allows the fatty acids, esters, aldehydes, organic acids, etc. to marry and recover from the mixing more quickly. Exhausted casks are perfect for this sort of thing, because when you have finished a product, you are not looking for new tannins or other oak extractive products, and the exhausted barrel acts as a sort of “lung”. I’ve used exhausted casks anywhere from 1 month to several years for marriage. But if you are using exhausted casks as oxidation vessels for whiskey marriage, then it is also important that you have the right maturation conditions, with proper temperature and humidity requirements for what you’re trying to accomplish.

After a finished whiskey is bottled, I always prefer that the newly bottled whiskey have a chance to “rest” before going out into the world to distributor’s warehouses, retail stores, or in connoisseur’s liquor cabinets. The bottling process is quite aggressive and can literally “shock” a spirit, so if you don’t allow at least the minimum amount of time for the bottles to rest, it will be very noticeable to the consumer. For this, whenever possible, I like to allow anywhere from 2 weeks to 1 month.

Now, on the consumer side of things, for connoisseurs who have taken an interest in blending 2 or more whiskeys at home and then putting them back in a bottle in order to experiment with new taste profiles, you might have noticed that when you first mix the whiskeys together and then taste it fairly soon after the mixing, it will usually be somewhat aggressive, hot, and angular. You might even notice that this effect is amplified the faster you mix the liquids together, whereas if you go more slowly when mixing the liquids, it will be less aggressive. It will also taste more aggressive if you vigorously mix the liquids together once in the bottle.

Why is this? Well, first of all, you have to be very gentle with alcohol, whether you are mixing barrels in a production setting or mixing different whiskeys together as a connoisseur. When you first mix different alcohols together, the molecular bonds are disjointed and interrupted, and thus, the mix will taste somewhat “spiky” and angular. You might not be very pleased with your initial attempt at mixing when you first taste it. But it takes time for the fatty acids, alcohol molecules, and other congeneric content to bond properly. And also, you have to remember that even when you allow a new mix to marry in a bottle, there is in effect some sort of “maturation” going on. Legally, of course, you cannot have “maturation” this way, but there are indeed chemical changes which are occurring in the presence of oxygen that take time to create.

As a general rule, I find that at least 1 month is necessary for this process to occur in a glass bottle. If you experiment with this at home, I would recommend making up a batch of 2 or more whiskeys that you mix that is large enough to take a taste of it every week to observe the changes. The first time you taste, do it immediately after you have blended your components together and take copious tasting notes. Keep the remainder of your sample in a dark, cool place. A week after you make the blend, taste it again and take notes. Do this every week for at least a month, and two months if possible.

Over time, you might notice that the blend starts to “relax,” become less angular each time you taste, until it eventually becomes rounder and softer on the palate. Notice whether or not new flavors and aromas develop. For example, you might notice some citrus notes developing, whereas those notes were not present in any of the component whiskeys. Occasionally, you might find that your home blend develops to a point, but then goes “flat” or dead, where it doesn’t seem very interesting anymore. In that case, try making minor adjustments to it, such as adding maybe no more than 5 mL of another whiskey component that might have more spice, sweetness, fruitiness, etc. You can always add more, but it is best to make these adjustments a little at a time and watch how they start to affect the mix before adding more.”

Value Proposition of Higher Proof US Whiskies

Whiskey geeks love higher proof whiskies.  We tend to like sipping whiskey neat at higher proof and the flexibility to add our own water to our desired proof.  In the heat of Houston summers, I often drink bourbon with a few ice cubes. Higher proof bourbon can hold up to ice without becoming too diluted.  In recent years the US distilleries and NDP’s have responded with expanded offerings at higher proof.

These higher proof offerings often come at significantly higher prices. The reality is you are paying a premium for something that simply has less water added to it.  It’s generally the same whiskey just bottled at a different proof. Knowing that, it becomes a math calculation to determine the premium you are paying for a more concentrated version.  It’s true that these versions often come in more fancy packaging. Some are not necessarily bottled at barrel proof, but perhaps at a marketing term of ‘Full Proof’ or just at a higher proof.  This is often done so they can have 1 label that covers all the possible proofs that will come out of any barrel or batch of barrels. Considering that I get my own water for virtually free, I decided to break some bottles down for price comparison.  This shows how much premium these higher proof bourbons carry. The chart below is based on pricing in my local market Houston for 750ml bottles; pricing varies some by region.

Barrel Proof premium rev 1

link to above – Barrel Proof spreadsheet

I’m sure I’ll get some feedback of my pairings. I’m not saying these are exact but I am saying they are close.  Is Stagg Jr really a barrel proof version of Buffalo Trace? They are the same mashbill and around the same age with just a difference in proof.  WP Boss Hog V is a 13 year MGPi Rye finished in secondary casks. WP Old World is 1 year off at 12 years and is MGPi Rye finished in secondary casks at a lower proof.  Blanton’s SFTB is EU’s current pricing converted to USD, but you still have to get it to the States.

As you can see the range is from an extremely reasonable zero % increase to a whopping 399% increase.  Overall we are paying significantly more for higher proof US whiskies. Are they worth this extra cost?  That always comes down to an individual’s personal preference. For me, I’m going to start drinking more OGD 114 and I need to go purchase some WT Rare Breed.

Next in this series I’ll look at how much premium producers are charging for finishing whiskey for a short period in secondary casks.

Proof Calculations computed using this calculator – https://homedistiller.org/distill/dilute/calc

Whiskey Show Advice & Etiquette

If you are a whiskey geek like me then you have probably attended whiskey shows like The Whiskey Extravaganza, Whiskies of the Worlds or numerous other events like these.  Producers at these shows pour various small samples of their whiskies. As a consumer it’s a great way to try new whiskies and get to know the brands a little more. For whiskey companies it’s a great way to introduce new whiskies to consumers as well as explain what make their brand unique.

One of my pet peeves is the tater that decides to have a 30-minute conversation with the brand rep while trying every single whiskey in the portfolio with a long line that stands behind him.  The proper etiquette is try 1 maybe 2 pours depending on the line and keep conversation reasonable but brief. Typically, the show’s lines tend to become shorter as the event progresses. So, if you want to have a longer more in-depth conversation stop back by later.  This advice also applies to the brand reps. You don’t need to start with “Our distillery began distilling 230 years ago” and continue with the complete history. I know it’s your job to educate customers on your brand, but develop a concise discussion that will cover the essential facts.  If a customer skips a table because the line is long both the consumer and vendor lose.

If you live in a major market like I do in Houston, these shows are frequent events.  Some are good and some are just a money grab, one and done type of shows. I suggest searching reviews on past events as well as looking at what companies will be pouring.  Respected shows will publish this list on their website. A danger sign that a show will not be very good is if the list is not made available to the public prior to the event.

I spoke with Kristopher Hart whose company runs a well-produced local whiskey event in Houston, Houston Whiskey Social, about managing lines.  Kristopher said “My goal has always been to shape the event in a way to prevent any build ups at the table to allow conversation to happen. We encourage a 10-14 person per Vendor ratio. So, if we have 70 vendors then we have 700-1000 people”.

Also keep in my mind it’s not a race or a competition to try the most.  Generally, if you tried every sample at one of these shows, you are not going to remember any of them.  Please use the dump buckets. Good shows will place these on every table or have them conveniently located.  Yes, that might be a great whiskey in your glass, but after you sampled it, it’s not being disrespectful to dump the rest.

Don’t be afraid to try new whiskies from producers you are not familiar with.  Yes, I love that sample of The Balvenie 21 PortWood, but if it is a whiskey you are very familiar with perhaps skip it and find something new to try.  I tend to try mostly new to me whiskies and from that I find a favorite that I will later purchase a bottle of.

Maker’s Mark answers label question

On the label of Maker’s Mark bourbon you will find “Maker’s Mark is America’s only handmade bourbon whisky – never mass produced”.   Looking through the COLA database, this statement goes back for at least 14 years.  I visited my local store and it was on every bottle I saw in both 750ml and 1.75liter.

Maker's Mary Never massed produced

I have visited close to 100 distilleries located all over the world.  Some have been very technologically advanced with computer screens and automation performing some of the work while others have been at the opposite end with every valve hand turned by a person.  I would say every distillery I have visited could make a valid claim of being handmade. At some point in the process hands are involved. For instance barrels are all rolled by hand. You will not find any definition of handmade in the TTB’s CFRs.  Maker’s Mark hand dips all of their bottles. So, I have no issue with Maker’s use of handmade on the label. They also claim never mass produced. Again, there is no legal definition for mass produced in the CFRs, so it is just a marketing statement.

What I found perplexing was their use of the word ‘only’.  With the boom of new craft distilleries in the US in the last 10 years certainly there are plenty of whisky distilleries operating on a smaller scale than Maker’s Mark with more hands-on involvement.  Frankly I was flabbergasted they would dare to make this statement.

When I started writing this blog post, the first thing I did was reach out Maker’s Mark to see if they would like to comment on this.  I received a response back the very next day. Here is the message:

“As the category has evolved, we have made updates to the label, including removing the word ‘only.’  Sometimes inventory takes a while to clear off the shelves, so it’s entirely possible that you’ve seen or even purchased bottles recently that still have this language (as noted in your picture). However, new bottles coming out of the Maker’s Mark Distillery today no longer include the word ‘only’.

I was expecting to post a hard take on this issue and see if it would convince them to change.  Looks like they outdid me; good for them for making this change. At least Bourbon geeks in the future will be able to quickly glance at a Maker’s Mark bottle and proclaim that’s a pre or post 2018 label change bottle.


Let me know in comments if you see a bottle with a label that reflects this new change.  Update – Confirmed sighting of new label as of November 2018.

 

Did my bourbon change in the bottle? 1 year test

Time for another round of “Did My Bourbon Change in the Bottle?”.  My previous post, Did My Bourbon Change in the bottle? discussed 2 prior tests done at 37 and 52 days.  For this test, I extended the time to one full year.

Before I get to that, I want to be clear that I’m testing if changes are perceivable to a group of testers.  This is different than saying the whiskey did not change at all. Also, my tests have been of modern bourbons and not of bourbon from a dusty bottle that has been sitting for 30 years in a sealed glass bottle.  Many critics of this will try to point to changes that occur while sitting in an open glass. That is a different case than opening and closing a sealed bottle. I’ve tried to test what I consider a real-world situation – open a new bottle, have a pour, reseal the bottle.  If you then sit that bottle aside and come back to it in 1 month, or 2 months or even a year, was there a noticeable change in taste?

For this test, I went back to Old Weller Antique (OWA) at 107 proof.  This OWA was a store private barrel pick and NCF (non-chill filtered).  The 1st bottle, 1 liter in size, was opened and over the course of 30 days I had approximate a ½ oz pour each day.  After each pour, the bottle was resealed tightly. At the end of 30 days bottle was about half full. At this point I put it inside a dark closet at normal room temperature for 11 months.

I invited my group of 10 testers to my house for a triangle blind tasting.  An unopened 2nd bottle from this same OWA barrel was opened right before the test.  Testers would taste 3 samples; 2 from the bottle that was open for 1 year and 1 from the just opened bottle, or vice versa.  Either way, one of the 3 samples is the odd sample and if change was perceptible enough then it should be identifiable. As before, I did not ask which tasted better, I only asked if they could identify the odd sample.

Out of 10 testers if they randomly guessed, one would expect 3.33 to correctly identify the odd sample.  So, when I scored up the results, I was surprised that 0 out of 10 correctly identified the odd sample.

One option I gave testers was to state no differences, but none elected this option.  They all believed they could tell a difference and they were all incorrect. One of the comments/questions I see posted on my tests is what was the experience level of my testers?  It has not been the same group each time, but for the most part it is folks I would consider whiskey geeks like myself. A few of the testers work in the industry. So, it’s an above average whiskey consumer group.

The conclusion is this whiskey did not change in the bottle enough to be identifiable to testers.  But did it change at all? To understand why the testers could not tell a difference we turn to GC/MS – Gas Chromatography – Mass Spectrometry.  I shipped sample bottles to a distillery with GC/MS equipment and they tested both samples at 12 different chemical points.  This tests measures levels in PPM.  The result showed these samples were virtually identical. 

OWA no ethano or PG chart

At this point, I’m done with testing “Did My Bourbon Change in the Bottle?”.  The power of the mind is strong; I’ll never convince all no matter how many tests I run.  If you still disagree on this based on your opinion, I would encourage you to perform your own blind triangle test.  I do intend to test “Does My Whiskey Change if Poured into a Glass and Allowed to Sit”; stay tuned in for those results.

BTAC fact sheets into spreadsheet

Just a quick blog post on BTAC info.  I took all the data from the fact sheets and put into a spreadsheet.  There are tabs at bottom for the 5 BTAC brands. You can quickly see how proof, ages, angel’s share, etc changed over time.  There are a few early years fact sheets missing on the Buffalo Trace website; if anybody has those, please let me know.

BTAC spreadsheet

 

 

Is it bourbon and can you trust review websites?

Let’s say you have a bottle Corn Whiskey, Wheat Whiskey, Rye Whiskey and Malt Whiskey and you blend those together with the Corn Whiskey being 51% of the total blend.  What have you just made? What if you are a licensed DSP and replaced bottles with barrels?

I hope my readers would know this product would be “Whiskey”.    If all the above were Straight, then it could even be “Straight Whiskey”.  What it is not and could never be is Bourbon Whiskey. Bourbon must be made from a grain mixture that is at least 51% corn with other grains that can be added for the remaining balance.  This must be done at the time of mashing/fermenting/distilling. It’s silly to think otherwise.

Yet that is exactly what a craft distillery in Florida did in creating the first Florida ‘Bourbon’.  Timber Creek Distillery separately distilled and aged these types of whiskies then blended them together to create their ‘Bourbon’.   They have a kit of these separate whiskies and encourage you to create your own ‘bourbon’ at home. They even trademarked this process at ‘Pureblend’.  

From their website:

Individual grain spirits are barreled individually after distillation.  Timber Creek individually barrels and ages each of their 100% whiskeys. Corn, Rye, Barley, Wheat and Oat corn whiskey’s are first given time to age before the distilling team selects the individual barrels. In order to blend bourbon whiskeys, specific barrels are hand selected since they have multiple grains. The hand selected barrels allow the individual flavors to blend to creating Timber Creeks Bourbon Blends.

As many distilleries do, Timber Creek hired a PR firm to send out samples to whiskey review sites. Note, my policy is this blog never accepts samples and if I ever do a whiskey review here, it will be of a bottle that was purchased at retail.  If you run a whiskey review site, you should know the definition of bourbon and at least question this process. That did not happen. The following ran articles on Timber Creek ‘Bourbon’.

Whiskey Wash – https://thewhiskeywash.com/reviews/whiskey-review-round-timber-creek-florida-bourbons

Bourbon Guy – http://www.bourbonguy.com/blog/2017/5/18/3-whiskeys-from-timber-creek-distillery3-whiskeys-from-timber-creek-distillery

-The Bourbon Guy updated his blog with some 2nd grade name calling but then states “…. blog is correct. I did make a mistake when I wrote this post. Though I know better, I didn’t call BS on the process that the distiller is using explicitly enough.”

Southern Living – https://www.southernliving.com/travel/travel/timber-creek-whiskey-distillery

Bourbon Sippers – http://bourbonsippers.com/timber-creek-distillery/

The Whiskey Reviewer – http://whiskeyreviewer.com/2017/01/timber-creek-florida-bourbon-review-011017/

Taste the Dram – https://www.tastethedram.com/single-post/2017/02/03/in-depth-whiskey-making-guide-by-camden-ford-of-the-timber-creek-distillery/

Timber Creek even managed to ‘win’ a few gold medals for their ‘bourbon’.  Of note, on their website they have now updated their product name and now properly call this Florida Whiskey.  Timber Creek is a 100% grain to glass distillery, so they earn my respect for that. I’ve reached out via email to the owner Camden Ford for comment about the change. He responded very quickly with a detailed response.  He felt no category in the TTB definitions accurately described their process. He stated “I have come to the conclusion that the goal of the descriptions were to attempt to describe common characteristics of each product and give them distinctive names that will let consumers understand that what they are tasting has a common set of flavor characteristics across brands and manufacturers in the same category.  With this view, I believe that what we make is, in fact Bourbon, in taste, profile, and chemical make up and follows the intent of the law.”

My reply was when you start trying to infer the intent of the law, you are going to have a 100 companies with 100 different interpretations and most of these are going to be wrong.

Please read the comments.  Camden has made several comments and received some good responses.

Yes, I do want a plastic straw with my cocktail

The number one google link about plastic straws in oceans says we use over 500 million straws a day and most of these end up in our oceans.  Another site says, ‘nearly every plastic straw winds up in the ocean’. I’ve seen alcohol industry groups such as USBG chapters and Tales of the Cocktail as well as some cities take this information and propose bans on plastic straws.  As Penn and Teller would say, bullshit.

By using some basic common sense, one would realize most straws wind up in garbage landfills and not the ocean.  Do folks think waste management companies specifically sort out plastic straws, load them on a boat and then dump them in the ocean? It’s complete and utter nonsense.   

Where did this oft cited 500 million straws a day number originate from?  From a 9-year-old boy who did a phone survey of straw manufacturers in 2011.  I swear I’m not making this up.  https://reason.com/blog/2018/01/25/california-bill-would-criminalize-restau

The more realistic number from market analysts puts the actual number at 1/3 of this kid’s “study”.  That’s still a lot of plastic straws, but that’s nowhere near as impressive as 500 million. How do plastic straws end up in the ocean?  Generally, they are blown there. So, it makes sense to look at eliminating plastic straws from places right next to waterways – ferries, boats, beach bars, etc.  If you live in a typical USA city, your waste straw is going into a landfill and not the ocean.

Plastic straws make up a very tiny percentage of the total plastic in a landfill.  Plastic straws are generally made from polypropylene, which is a highly recyclable plastic resin.  If one wants to reduce plastic going into landfills, it’s easy enough to ask for no straw or to carry one’s own reusable straw.  If you are a restaurant or bar owner and are considering going ‘strawless’ to save the ocean, your heart might be in the right place but the logic is flawed.

 

House Brands

The big liquor stores love their ‘house’ brands and will push them hard to customers. Why? It’s all about the money. Here is a bourbon brand found pretty much only at Total Wine – 2 Stars. It’s KY Straight Bourbon Whiskey at least 4 years old at 86 proof – really some fairly decent bourbon at a cost of $39.99 for a 1.75 liter handle. It’s produced by Sazerac from Bourbon made at their Barton 1792 distillery. Or you can buy practically the same KY Straight Bourbon Whiskey at least 4 years old at 86 proof under the Barton brand, which is not a house brand, for $19.99 for the same size.

As Richard Seale of Foursquare Rum once said ‘drink what you like, be careful what you pay for’

2 StarsVery Old barton

Bourbon with flavor packets?

Most whiskey aficionadas know that Bourbon can’t have any added flavors or coloring.  This is true regardless if the Bourbon is labeled Straight or not. If you question this, it can be verified by reviewing Ch. 7 of the TTB BAM.  This contains a chart of all spirit types and if HCFBM (harmless coloring flavoring blending material) can be added. Both Bourbon and Straight Bourbon are checked as not allowed.  For other types of whiskey, such as Rye or Wheat, which are labeled as Straight, HFCBMs are not allowed. However HFCBMs are allowed in these other whiskey types if not labeled as Straight.

HFC edited
I was surprised when I reviewed the COLA label approval for the newest Blood Oath Pact 4 Bourbon and found a formula.  
27 CFR 5.26 (a) states ‘an approved formula is required to blend, mix, purify, refine, compound, or treat spirits in a manner which results in a change of character, composition, class or type of the spirits’.  TTB regulations commonly require formulas when HCFBM are added to spirits.  

Blood Oath Flavor Packets


This brings us to when is a Bourbon not really a Bourbon?  Spirits have dedicated class types by the TTB. Straight Bourbon is class type 101; Bourbon is 141.   When you start messing with bourbon by adding flavor packets or secondary cask finishes, these products are no longer legally bourbon.  They become class type 641, which is a catch all for ‘Whisky Specialties’. Blood Oath Pact 4 is not a bourbon; it was approved as a Whisky Specialties.  Formulas are proprietary information so who knows what they might have or have not added to this. For these products, the TTB allows Bourbon to still be used on the front label, but the extra process must be listed.  They give an example in the BAM of adding coloring to bourbon. The example specifically states that the product is no longer Bourbon, but the label can state “Straight Bourbon Whisky with Yellow #5 added”.  

If someone put me in charge of the TTB, this would be the first thing I would change.  I would not allow these products to be called Bourbon and would make the front label say what they are – Whisky Specialty.   For my money, I will stick with Straight Whiskies.


Age statements on straight whiskies are now meaningless

Many American whiskey brands have been dropping age statements as the bourbon boom continues to erode stocks of aged whiskey.  As a consumer, I have always appreciated age statements. If an American whiskey has an age statement on the bottle, I have accepted that information as fact.  This blog post will touch on US federal laws regarding spirits labeling which some might find boring. Our laws on spirits are found in the Code of Federal Regulations – CFR’s.  Specifically, laws regarding alcohol are found in CFR Title 27. The CFR’s can be confusing so the TTB developed the Beverage Alcohol Manual – BAM. The BAM is an attempt to take language from the CFR’s and make it more approachable.  In addition, the TTB from time to time will issue additional guidance through ruling’s, industry circulars and other publications including TTB FAQ’s.

27 CFR 5.40 (a) addresses statements of age for American whiskey.  This regulation can be found at:https://www.law.cornell.edu/cfr/text/27/5.40

The law states that for straight whiskies over 4 years old, statements of age are optional.  If an optional age statement is included it shall appear in the same form as a whiskey that requires an age statement.  That form shall be the age of the youngest whiskey in “____years old”. The law does allow for straight whiskies of multiple years to be stated if the percent of each whiskey is disclosed.

This information is also covered in Ch. 8 of the BAM.  https://www.ttb.gov/spirits/bam/chapter8.pdf

The BAM points out age may be understated but not overstated.  This means it is fine to bottle 8 year straight whiskey in a product that has a 6 year age statement.

The TTB also has a FAQ on spirits that addresses age statements:  https://www.ttb.gov/spirits/faq.shtml

This FAQ has the specific question of:

How should age be stated if the whisky consists of a mixture or blend of whiskies with different ages?

If the whisky contains no neutral spirits, the age must be stated either as the age of the youngest whisky, or as a statement that includes the age of each whisky in the mixture or blend, and the percentage of that whisky in the mixture or blend. If percentages are listed, they must be based on the percentage of the finished product, by a proof gallon basis, contributed by each listed whisky, and the percentages listed must add up to 100%.

This FAQ also gives acceptable formats for age statements:

What are examples of acceptable formats for age statements?

The following formats are acceptable:

  • _____ years old.
  • ____ months old.
  • Aged _____ years.
  • Aged at least ____ years.
  • Aged a minimum of ____ months.
  • Over ____ years old.
  • Aged not less than ____ years.
  • ___% whisky aged __ years; __% whisky aged ___ years.

If you read the above and followed the links, you should now be well versed an age statements on labels.  I was recently made aware of an interesting statement of age found of the back label of current Wild Turkey 101.   I love WT 101 and I think it is an incredible value for an everyday bourbon.  The label can be found here:

https://www.ttbonline.gov/colasonline/viewColaDetails.do?action=publicFormDisplay&ttbid=16006001000132

This label was approved on January 28, 2016. The back-label states ‘bourbon is perfectly aged for up to six to eight years’.   Obviously, this does not comply with the TTB acceptable age statements.  It would be fine to state Aged 6 years. Or they could state __% aged 6 years; __% aged 8 years.    Stating ‘up to’ does not meet the acceptable formats.  Stating a range of ages does not meet the acceptable format.

When labels are submitted for TTB approval the contact person who submitted label is listed.  I took this name and discovered it was a regulatory compliance director for Campari. I found email contact info and emailed asking about the discrepancies pointing out the same laws I noted above.   After 2 weeks I had received zero response.

I still wanted to find out why this label with an age statement such as this was approved, so I emailed the TTB.  In past blog posts I have complained about some of the labels that the TTB has approved, but I will give them credit in that anytime I have contacted them, I have always received some type of response.  In this case it was a phone call from Marsha Heath, a 20+ year veteran of the TTB. Marsha directed me to 27 CFR 5.40 (e) (2) regarding Miscellaneous Age Representations and pointed out the sections that have been bolded:

If any age, maturity, or similar representation is made relative to any distilled spirits (such representations for products enumerated in paragraph (d) of this section are prohibited), the age shall also be stated on all labels where such representation appears, and in a manner substantially as conspicuous as such representation: Provided. That the use of the word “old” or other word denoting age, as part of the brand name, shall not be deemed to be an age representation: And provided further, That the labels of whiskies and brandies (except immature brandies) not required to bear a statement of age, and rum and Tequila aged for not less than 4 years, may contain general inconspicuous age, maturity or similar representations without the label bearing an age statement.

The labels of whiskies not required to bear a statement of age – This would apply to straight whiskies over 4 years, which includes WT 101

may contain general inconspicuous age, maturity or similar representations without the label bearing an age statement 

Marsha declared the WT 101 back label statement of ‘bourbon is perfectly aged for up to six to eight years’ is ‘general in nature and inconspicuous located’ and therefore allowed by this section.  A few days after this phone call, I received an email response back from Campari that provided the exact same response. Enough so I would be very surprised if there was not some type coordinated response to my inquiry behind the scenes.

Stating 6 to 8 years old is not general, it’s specific and noticeable.  6 to 8 years is not a wide range and I suspect WT includes a good percentage of the 8 year old whiskey.  For me, the issue is not about this Wild Turkey label, the danger is that now a precedent has been set. If the TTB enforces this interpretation consistently to all brands, then there is nothing to stop the next brand from stating 4 to 25 years on the back label of a straight bourbon when just a very small fraction of the whiskey is 25 years old.  This would effectively render age statements meaningless to consumers.

Spirit award shows are all crap

A local craft distiller told me they get at least one phone call or letter every week asking them to participate in a spirit award show.  They all function about the same.  Send them a check for $500 per spirit entered along with 2 bottles. Practically all spirits entered will ‘win’ some type of award.  One show mentioned was the Beverly Hills Award show.  This is promoted as an “elite competition recognizing the very best”; winners could promote they ‘won’ an award from a prestigious address – Beverly Hills.  I did a little research and discovered their prestigious address was a rental post office in Beverly Hills. This rental post office advertised they specialized in folks wanting a Beverly Hills address and would forward mail/packages to wherever needed.  This is a complete pay to play sham.

Uneducated spirit buyers (i.e. whiskey taters) do like to see ‘awards’ on retail shelf talkers. It makes them feel good about their purchase. Most also have no clue there is more than 1 award show or anything about how they work.

A huge flaw in every award show is that they depend on the producers to select send in bottles for award consideration vs the award show buying the bottles.  Lots of whiskies are single barrel products that have variation between barrels. It’s very easy for a producer to pick a honey barrel to be judged.  That barrel might not taste anything like the rest of the barrels bottled. Even if it’s not a single barrel whiskey, there is nothing stopping a less scrupulous producer from gaming any bottle submitted.

Another way these shows are flawed are by the categories they purposely create.  How about Single Barrel Wheated Whiskey from 2 to 4 years old? If the field is limited to just a few possible entries, every whiskey will ‘win’ an award.  I’ve never seen a shelf talker that states the category the spirit won an award in. Since not all spirits are entered in every award show there is never a true best of award; it’s only best of what was entered.

The largest award show is the annual San Francisco World Spirits Competition.  In 2017 2,253 spirits entered this competition and 2,083 of those ‘won’ a medal.  That’s a 92.4% win rate; guess the judges are not very strict.  That year the winner of best whiskey went to an unreleased to retail honey barrel product.  I know a judge, Fred Minnick, in this competition. I do give them credit that spirits are truly blind tasted, but judges do talk to each other and try to sway influence.  The founder was recently interviewed by Kenny Coleman on his Bourbon Pursuit podcast show;  Kenny’s Interview  Kenny did ask about producers entering honey barrels bottles and the founder sidestepped the question and does not think it happens with spirits.  In 2017, Ben Milam won a double gold, SFWSC’s highest medal, for their Single Barrel Bourbon. Ben Milam sourced this whiskey from MGPi. I don’t know what they turned in to be judged but I bought a bottle at retail. I put in a blind tasting of 15 participants with a total of 20 whiskies, all blind to participants.  It finished 12th; hardly worthy of a double gold award. So who are you going to trust? The 2018 award winner was again another producer submitted single barrel product.

How long should these awards last?  Producers change production methods over time and NDP’s switch sources which means the whiskey changes as well.  Tito’s entered the San Francisco World Spirits in the second year of the competition, 2001.  Tito’s did ‘win’ a double gold medal. They never entered again and yet to this day still brag about that gold medal and the other Vodkas they beat in their advertising.  What they don’t say is 2 other Vodkas also ‘won’ double gold. The top winner also is stated as Best Vodka and that year it was not Tito’s; it was Wodka Wyborowa Vodka from Poland.

The only award the really matters is the one you give a whiskey. Tasting whiskey is very subjective; you may or may not agree with any so called expert panel.  That leads to the question of how to know if you like a whiskey before purchasing it? I have a goto bar that always brings in new whiskies and generally will give me a small taste to sample.  In my market there are several whiskey shows which is a great way to try new products. Another option is to have whiskey get togethers in your local town where everyone brings a bottle to share. I’ll repeat the only award the really matters is the one you give a whiskey.

This leads us to whiskey tater reason #6. Purchase a bottle of whiskey because a shelf talker mentioned it ‘won’ an award

So, you want to give a whiskey drinker a gift of a bottle of bourbon?

If you start doing a lot of tater things in whiskey, your normal friends will eventually have an occasion to buy you a gift and they will decide another bottle of bourbon would be perfect.  They will then try to find that ‘perfect’ bottle.  In the past, I’ve often been gifted either Basil Hayden’s or Blanton’s.  Basil Hayden’s has very elaborate bottle packaging and Blanton’s has very pretty bottle.  I’m pretty sure those shopping for me bought based on packaging.  I prefer Blanton’s of the two, but I’m not going to complain about free Straight Bourbon.

Sometimes the person will turn to online bourbon groups for a bottle suggestion.  This is a huge mistake.  The online tater groups will likely suggest all kinds of bottles that are rarely available at retail.  The gifter will venture to their local liquor store where they will become frustrated because nothing on their list is available.  I witnessed this plenty of times in the bourbon aisle of my local store.  Yes, the store salesman will take and place their name on the list for that bottle of Pappy Van Winkle 23.  The Blanton’s I was gifted before is now on this hard to find list.  Or the taters will suggest expensive shelf turds like Whistlepig Boss Hogg if the gifter’s budget allows it.

I recall the days 12 years ago where I could ask for BTAC bottles from relatives as Christmas presents and they could easily go buy these.  Sadly, those days are long gone.  The $100 price point is one that is often given as the gift amount.  The $100 price point of bottles that are likely to still be on the shelf is also the home of some biggest tater bottles out there like Blood Oath or several of the Jefferson’s.  I suspect those producers pick that price point for this reason.

I think it’s unrealistic to expect the occasional gift giver to venture into secondary markets.  So, I’ll make some basic suggestions of good solid Straight Bourbons that are easy to find in most markets as of 2018.

$30 – Elijah Craig
$45 – Wild Turkey Rare Breed
$65 – Booker’s

There is really no need to spend any more than this.  I know if I were gifted any of these bottles and I would be very happy.  Now to post this to Facebook so all my friends see it.

Did my bourbon change in the bottle?

I often see posted in bourbon social media sites people comment that the initial first taste from a new bottle of bourbon was not good but after letting it ‘open up’ a few weeks later it was completely different and so much better.  Bourbon ages for years in permeable oak barrels, so this theory that it changes after opening a bottle made little sense to me. What I have always suspected is that this difference is due to changes in your palate. Your palate, or how you perceive taste, changes constantly.   

I wanted to test this and it’s an easy enough test to perform by purchasing 2 identical bottles of bourbon.  Open one up and drink from it.  Keep the other one sealed.  At some point in time later, have a drink from both bottles side by side and see if there is a difference.  I did this myself a few times and could never tell any difference, but I’m only one person, so it was a very limited dataset for proof. In 2017 I decided to test this with a larger group.   I also introduced a triangle test to this.  Testers would taste 3 samples; 2 from the previous opened bottle and 1 sample from the just opened, or vice versa.  Either way, one of the 3 samples is the odd sample and if change was perceptible enough then it should be identified.  This test is objective in that it is designed to test if any change has occurred.  It does not test if that change is better or worse which is much more subjective.

My first test of this was with Old Weller Antique which is 107 proof.  The timeframe from the bottle being opened to test was 37 days.  The result was that there was no discernible difference.  I posted more details on this here OWA change test

I shared that result in several bourbon groups.  Many were convinced that my study was flawed.  They commented that a wheated bourbon would not change much, or my timeframe was too short or it needs to be a barrel proof bourbon.  I listened and setup up another round of testing.  This time it was with bottles of a 124.4 barrel proof Four Roses Single barrel pick.  Picked by a bar in Houston named Little Dipper.    One bottle I opened and took small pours of about every other day until the bottle was half empty.  The time frame was increased to 52 days.

Little dipper bottles a

We had 12 testers.  4 said they could not tell any differences.  6 testers thought they perceived a difference but their pick was 1 of 2 identical samples in the triangle test.  2 testers correctly identified the odd sample.  Since odds of random guessing would be 4 correct answers in this test, the conclusion is no discernable difference found.

Stay tuned as I have another test and that timeframe will be 1 year.  The results will be posted around June.  I suspect this one will have a noticeable change, but I won’t know for sure until tested.  As far as short term, under a month or two, I will call this myth busted.