Wednesday, July 17, 2013
ADI's New Certification System; A Step In the Right Direction Or More Mud In The Water?
Over the weekend, the American Distilling Institute (ADI) announced a new certification program for craft spirits. You can read what ADI has to say about it here.
Clay Risen, in his 'Mash Notes' blog, describes the two certifications ADI is offering as "'Certified Craft Distilled Spirits' — distilleries that make everything in-house — and 'Certified Craft Blended Spirits' — which buy distillate or aged product but then add a step, like redistilling or further aging, that 'shows significant craftsmanship in the creation of flavor.' Of note, ADI insists that 'simply buying bulk spirits on the market and watering it to proof does not constitute craft and those spirits are not eligible.'"
If only the actual definitions were as simple and straightforward as Risen's paraphrase. Alas, they are not.
To be effective, a certification system has to be a couple of things. 'Trustworthy' is probably foremost, but 'unambiguous' and 'easy to use' are critical too. Unfortunately, ADI's new system raises questions on all three fronts.
The fact that ADI has launched this program with hundreds of products already certified hints at a not-very-rigorous verification process. According to the website, these were "pre-certified by ADI staff." Dig deeper and you'll see that what ADI offers is essentially self-certification. The producer submits an application and if they answer all of the questions correctly, they get certified. This is sometimes called first party certification. It is, in effect, an honor system.
As you read further, you learn that the only sin ADI seeks to banish is when 'large liquor conglomerates' create 'pseudo-craft brands' to 'share the spotlight' with craft brands. They continue:
"At a recent tasting in California, a major distributor operating in several states released the menu for their craft portfolio. It included such venerable 'craft' brands as Buffalo Trace, Woodford Reserve, Rittenhouse Rye and Jack Daniels Unaged Rye. These are all good whiskeys -- but craft? Apparently, there is some confusion here and education clearly needs to happen. If we don't educate the public, others will. ADI is taking a stand to inform the distributors, the retailers, bartenders and general public, to clear up the confusion as to what brands are craft and what are not. To protect the distiller and aid consumers and buyers, who may have difficulty researching the background of every label, we have created a certification for craft produced spirits."
Certainly an admirable goal, but in what way is Breuckelen Distilling Company New York Wheat Whiskey, to pick one at random, more craft than Rittenhouse Rye? In other words, what is craft?
It's a question this blog has been asking so-called craft distillers since at least 2008.
Wikipedia offers this observation that's not quite a definition but addresses the dilemma well. "The mass production of goods by large-scale industry has limited crafts to market segments in which industry's modes of functioning or its mass-produced goods would not or cannot satisfy the preferences of potential buyers." That suggests that a craft-made product is one that has identifiable characteristics that cannot be found in mass-produced goods of the same type. It talks about the product, not the producer, and the product's characteristics.
Unfortunately, there is very little in the ADI certification process that ensures or even defines a ‘craft’ product. Instead, craft is equated with small and independent. If you are small and independent (and those terms are defined) then you're craft. The requirements that might be interpreted as referring to ‘craft’ are so vague, broad and contradictory that they include everything and exclude nothing, process-wise. For example, "Craft distillers produce spirits that reflect the vision of their principal distillers using any combination of traditional or innovative techniques, including fermenting, distilling, re-distilling, warehousing, infusing, or blending."
Warehousing? Infusing? Blending? In the definition of 'craft distilled spirit'?
Elsewhere, ADI seems to get at the crux of the matter. The 'craft distilled' definition requires that the product be "PHYSICALLY distilled and bottled on site." (Emphasis in the original) One wonders in what other state, other than physically, could the product be distilled and bottled on site? Is there some way a product can be distilled and bottled on site other than physically? Metaphysically?
The 'craft distilled' certification also requires a TTB-approved ‘distilled by’ label statement. That's more like it. Is ADI at least requiring applicants to submit their COLAs to prove compliance? There is no evidence that they are and some evidence that they are not. (The application doesn't ask for it.)
For example, a search of COLAs at TTB’s web site was unable to find a COLA for 'Widow Jane Wapsie Valley Whiskey,' a product on the pre-certified list. Window Jane is a brand name under which Cacao Pietro in Brooklyn is currently selling a rebottled Kentucky bourbon that they obviously did not distill. They also have an approved COLA for a 'Widow Jane Whiskey' that is distilled at Cacao Pietro. Using the same brand name for both would seem contrary to the desire for simplicity and transparency for the consumer. It's more like a bait and switch. Clearly, ADI's intention is for producers who sell both homemade and bulk products to clearly differentiate them. Is Cacao Pietro acting in that spirit? Or are they trying to obscure the difference, using the 'craft distilled' halo to sell a product made by one of the evil 'liquor conglomerates'?
A worse offender appears to be Old Smoky Distillery. They have 32 approved COLAs on file. They all say 'bottled by' not 'distilled by' on the label, yet there are four Old Smoky products on the ADI 'pre-certified' list that are 'certified craft distilled.' One is just identified as 'Old Smoky Moonshine.' Are there, in fact, four products in the huge Old Smoky portfolio that say 'distilled by' on their labels? Even if there are, how is the consumer supposed to separate them out? And doesn't Old Smoky, America's most-visited craft distillery, want everybody who buys a souvenir of their visit to believe that juice was all made right there?
It is widely known if perhaps not readily admitted that the Old Smoky Distillery makes only a fraction of the spirit it sells, which it supplements with very non-craft grain neutral spirit (i.e., vodka), bought from a 'large liquor conglomerate.'
So how useful is this certification to consumers? Perhaps the answer is here, in the ADI's explanatory materials: "The license to use this mark is now a benefit of full membership for qualifying DSPs that complete the application process." If you're little, and independent, and a full dues-paying member of ADI, then of course your products are craft. Here's a sticker that says so.
This is a brand new program and all of these issues can be addressed. Here's hoping that happens soon.