Monday, February 16, 2015
Whiskey and the Perils of Popularity
Whiskey is popular again, especially American whiskey (e.g., bourbon, rye). That means the liquid itself is popular but it also means the idea of whiskey is popular, which means producers will lead you to believe you are drinking whisky when you are not.
This is nothing new in the United States. We are the only country in the world that allows an unaged distillate (corn whiskey) to call itself whiskey, and we are the only one that allows a product that is 80 percent vodka to call itself whiskey, i.e., blended whiskey. We even allow a product that is merely 5 percent whiskey to call itself 'spirit whiskey.'
Today, the issue is so-called 'flavored whiskeys,' none of which use the TTB's Section 5.22 (i) Class 9, the rule where flavored whiskey is defined as "whisky...to which [has] been added natural flavoring materials, with or without the addition of sugar, and bottled at not less than 60° proof."
Most of these products, and all of the most popular ones (Fireball, Jack Daniel's Honey) are distilled spirit specialties, a catch-all category that isn't really a category at all. The rule is simply that the label must display "a truthful and adequate statement of composition." So Fireball is allowed to be called 'Cinnamon Whisky,' defined below in smaller type as 'whisky with natural cinnamon flavor.' Red Stag by Jim Beam is 'Kentucky Straight Bourbon Whiskey Infused with Natural Flavors,' as is Knob Creek Smoked Maple. Crown Royal Regal Apple and Crown Royal Maple Finished are 'a blend of whiskies infused with natural flavors.'
Jack Daniel's Tennessee Honey, like Fireball one of the most popular flavored products, goes a different route. It is 'Honey Liqueur Blended with Jack Daniel's Tennessee Whiskey.' The flavored products from Wild Turkey, Evan Williams, and Rebel Yell use similar language.
With the 'whiskey with...' products such as Red Stag and Fireball, you at least know all of the alcohol in the product is whiskey. That's not true when one of the ingredients is a liqueur. When you see the word 'liqueur' on the label, it is likely that some of the alcohol in the product is grain neutral spirit, i.e., vodka, and you can't be sure how much.
But here is a clue. Section 5.22 (h) (2) defines 'rye liqueur' and 'bourbon liqueur.' Nobody uses that classification either. Why not? Probably because it requires that the product derive at least 51 percent of its alcohol from the named whiskey type. It is safe to assume, then, that the liqueur component of these products does not meet that minimum standard. When the label says 'liqueur and whiskey' you have no idea what the ratios are, so it's possible that most of the alcohol in the product is actually vodka,
None of this is presented as a criticism of any product, company, or consumer. It is an exercise intended to keep me sharp (interpreting the rules is hard) and help all of us know what we are really drinking.