The other shoe has finally dropped on the saga of Jack Daniel's Tennessee Rye, as the product is now appearing in stores. A quick recap follows, but if you want to read everything go here, then here, and most of all here. If you want to get into the 'white whiskey' question a bit more generally, go here.
The gist of the story is this. Back in October, Jack Daniel's announced that it was launching an unaged rye, a straight-from-the-still preview of what, in the fullness of time, will become a properly aged Jack Daniel's Straight Rye Whiskey. They said it came off the still at 140° proof (70% ABV), yet the label on the prototype bottle classified it as 'neutral spirit.'
That made no sense, since 'neutral spirit' is vodka and the sample they sent me definitely was not vodka. So I inquired. In response, spokesfolk for Daniel's stated that, "By this ruling, it is assumed that the TTB considers all whiskies (except corn whisky) to be neutral spirits until they enter the barrel for maturation. Jack Daniel’s packaging and legal departments argued that the Tennessee Unaged Rye should be labeled as an 'unaged whiskey' which we felt more accurately described the nature of the product to the consumer, but the TTB ruled against this proposal and would only approve the label under the category 'neutral spirit.'"
The TTB, however, took a different position in correspondence with me. Thomas K. Hogue, Director of Congressional and Public Affairs, wrote that, "The regulations are pretty straight forward. Whisky is defined ... as an alcoholic distillate from fermented mash of grain produced at less than 190° proof that must be stored in oak containers. Neutral spirits must be distilled at 190° or higher. A product that is made from fermented mash of grain and produced at less than 190° of proof but not stored in oak containers would be a distilled spirits specialty product, as it would not meet any of the standards of identity." It could, according to Hogue, be labeled as 'spirits distilled from grain.'
The product has finally been released and here is the actual label.
So, does this mean The Chuck Cowdery Blog forced mighty, mighty Jack Daniel's to change a label? You can decide that for yourselves. The evidence is before you. By the way, when this all began to unravel I asked the Jack Daniel's spokesfolk to comment, but they haven't. They let their new label do the talking for them.
18 comments:
I wouldn't say "forced". I'd say "helped" or "enabled", since they didn't want to label it the way ATF said they had to in the first place.
Nice work Chuck! I don't know that I've ever heard of the TTB taking action in response to a non-party in such a way. Really impressive.
Now that you've shown yourself to have some serious pull with the TTB, do you think you could get them to enforce the rest of their rules that seem to slide (state of distillation, age statements, etc.)?
Congrats, Chuck. If JD is going to get pushed around - they couldn't wish for a nicer or more knowledgable guy to do it! Logic has appeared to have prevailed here. Thanks for defending the "whiskey geek" end of the field!
You're right of course, Rob, in that this is certainly better for JD, but let me have my little moment. I am in regular communication with TTB, Sku, on a variety of issues. We seem to have developed a pretty good working relationship.
I didn't mean to take your moment away! I think it's great that you you got TTB to change their mind and actually pay attention to their own rules.
So, how does that white dog rye actually taste?
Like rye whiskey white dog. Milder than most, probably because of the charcoal filtration. Bright citrus, a little grass. It's on the thin side, which you would expect with so little corn and no wood sugars yet.
I've bought one bottle of white dog in my life. One was enough.
Now I don't feel quite as big an idiot for not having tried rye whiskey white dog yet. I have a few samples I never quite get around to tasting...
Chuck, have you brought up some of the issues that Sku mentioned? It's getting pretty ridiculous out there.
I'm in regular contact with the TTB as well. Of course all my communication is one sided, I complain about obvious violations and they do nothing.
Totally agree with sku and love to see them start enforcing rules regarding state of distillation on label.
Where I've had success it has been, like with the JD Rye, where I can point to a COLA, then to some facts as given by the producer, that render the label wrong. There's not a lot of feedback. As with the JD Rye, I have to wait until the product is released to see if anything was done. We don't have long, philosophical discussions.
What's the point of releasing an 80 proof white dog? Well, other than to say "hey, we have an unaged spirit too!"
Is this a rye whiskey? The largest text on the label says "Tennessee Rye," which suggests to me that this is a rye whiskey made in Tennessee. Maybe the TTB let it through because the word "Rye" is not followed by the word "Whiskey," but that seems lame, because the public surely considers a bottle of "rye" to be "rye whiskey" and not some other product. I would think it is in JD's best interest to guard the integrity of the text "Tennessee Rye," rather than let it be something other than rye whiskey made in TN.
What they are selling is not rye whiskey because it hasn't been aged, but they are aging some of the same liquid and that, once it has touched wood, is rye whiskey. After two years in new wood, it will be straight rye whiskey. Will consumers consider this current product to be 'unaged rye whiskey'? Yes, which is the intention, but they can't put the word 'whiskey' anywhere on the label due to the lack of aging.
I think I would have stood it in oak barrels for 24 hours and called it "Very Young" Rye Whisky and eliminated the challenge, and made a marketable product rather than unaged rye whitedog. Interested to see 1st POS suggesting uses for it!
I've seen these in stores now for around $50. That seems pretty high for an unaged spirit. Is it simply a rare product right now and that's why it's so expensive? I was curious about the taste, but not $50 curious.
I too assume it's rarity that justifies the price.
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