Distiller Feedback on Proposed Changes

**** Thank you for all the responses! The survey is now closed. We will be sending the survey data to the ACSA board for official submission to the TTB. We will be sending the meta-data to all the partocipants who left emails in the next month or so. ****
Whiskey Systems Online seeks to summarize and collect feedback from craft distilleries on the proposed changes to TTB regulations. Click OK or scroll down to start the survey. Estimated time to complete the survey: 4 min

Indicate for each row if you are Opposed, Neutral, or In-Support with the summary of proposed changes below. If you Strongly Oppose or Strongly Support, please add a comment with your thoughts and feedback. We will be summarizing the feedback and sending it on for an official comment submission. 

The public comment period officially ends March 26, 2019 but we would like all Craft Distiller feedback by Dec 31, 2018 to consolidate the feedback. 

Please keep comments productive. Here is a great link on notes on making effective feedback:
https://www.regulations.gov/docs/Tips_For_Submitting_Effective_Comments.pdf

Here is a link to the full text of the TTB Proposed Changes:
https://www.regulations.gov/document?D=TTB-2018-0007-0001

Important note: In addition to this survey, there are additional ways for the distiller community to provide feedback including giving comments directly to the TTB and participating in a separate survey from the American Craft Spirits Association ACSA coming Saturday, December 15th. 

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* 1. Distillery Name

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* 2. Email address (will send you the final consolidated feedback submitted)

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* 3. On the below proposed changes, indicate your preference and leave comments as needed.

  Strongly Oppose Oppose Neutral Support Strongly Support
OAK BARREL -- Defining "Oak Barrel": If an oak container is used for aging spirits, it must be a "cylindrical oak drum of approximately 50 gallons capacity". It is unclear if smaller barrels (example 15 to 30 gallon barrels) or larger barrels (60 gallon barrels) would be permitted to age spirits if this is approved.
TOLERANCE -- Expand tolerance for labeling alcohol content to 0.3 percent ABV (or 0.6 Proof) below AND above the labeled alcohol content. Example new tolerance for 80 proof would be from 79.4 PF to 80.6 PF.
MULTIPLE DISTILLATIONS -- Add new rules for multiple distillation claims.  Currently allowed if they are truthful statements.  Proposes defining a distillation as a single run through a pot still or one run through a single distillation column of a column still. (For example, not 12 times distilled if there are 12 trays on a column still.)
GRAINS -- Defining "Grain": Whiskey can be made from “grain,” which they will now be defined as including, “cereal grains as well as the seeds of the pseudocereal grains: amaranth, buckwheat, and quinoa.”
TWO BARREL TYPES -- Add the labeling requirement for whiskey stored in two different types of barrels, i.e. whiskey stored in oak and then put into a finishing barrel.  This spirit becomes a distilled spirit specialty and must be labeled with a statement of composition.
ORIGINAL DISTILLATION -- Requiring "State of Distillation": For whiskey, the new rules require that the state of original distillation must be clearly shown on the label.
AGAVE SPIRITS -- Add a new classification called “agave spirits”, currently a DSS.  Proposes that the mash be made from at least 51 percent agave and may contain up to 49 percent sugar.
SPELLING -- ‘Whisky’ and ‘Whiskey’: New rule specifically clarifies that both spellings are acceptable. (Although this has always been true).
LABEL WHISKEY TYPE -- Require the type of whiskey on the label if the spirits meet the standards for that type (example bourbon whiskey, straight whiskey, rye whiskey, etc.) versus designated simply as `Whiskey.' For example, if any whiskey is not labeled “straight,” then it did not meet the requirements.
NO BLENDERS BOURBON -- No coloring, flavoring, or blending materials in bourbon: This is has been a long time practice but now is clearly stated.
RULES FOR PROOF -- Defines rules for the use of “barrel proof,” cask strength,” “original proof,” “original barrel proof,” “original cask strength,” and “entry proof” on distilled spirits (see section, § 5.87 for definitions),
UNAGED / WHITE Whiskey -- Defines/Approves Unaged Whiskey and White Whiskey: This officially creates a new category of whiskey that never touched a barrel instead of touching a barrel for a short period of time to meet "whiskey" requirements. Whiskey that has been filtered to remove all colored can be called "White Whiskey".
AGE STATEMENTS -- Allow age statements on all distilled spirits, except for neutral spirits. Grain based spirits may already contain an age statement. For example, adding an age statement to barrel-aged gin.
CHANGE PRODUCED BY -- Clarifications of “Produced By,” etc.: The TTB states that using ambiguous terms like “produced by,” “made by,” and “manufactured by” are meant to be confusing. Definitive phrases like “bottled by” and “distilled by” should be used.  Ambiguous terms are inherently ambiguous, or used to mislead, convey no useful information to the consumer, and should simply be prohibited.

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* 4. Thank you for your feedback! If you have any other thoughts or comments please add them here. 

For a great, consolidated list of ALL the TTB proposed changes, visit:
https://whiskeysystems.com/2018/12/14/whiskey-systems-online-summarizes-ttb-proposed-changes/

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