Tuesday, May 7, 2019

What the Market Calls 'Flavored Whiskey' Is Not What TTB Calls 'Flavored Whiskey'



Jack Daniels, as everyone knows, is whiskey, Tennessee whiskey, to be exact.

But Jack Daniel's Tennessee Fire is not whiskey. As the label clearly explains, it is "cinnamon liqueur blended with Jack Daniel's Tennessee Whiskey." Since the first ingredient listed is typically the largest component, we can assume that's the case here.

The official classification of this product, according to the rules of the Treasury Department's Alcohol Tax and Trade Bureau (TTB) is 'other specialties and proprietaries.' It is, in effect, a pre-mixed cocktail, the ingredients of which are cinnamon liqueur and Tennessee whiskey.

TTB has a 'flavored whiskey' classification, but no one uses it. Most producers of what the market calls 'flavored whiskey' use either 'other specialties and proprietaries' or 'whiskey specialty,' which are basically catch-alls. Or they use the liqueur classification.

TTB defines flavored whiskey as whiskey to which has been added, "natural flavoring materials, with or without the addition of sugar, and bottled at not less than 60° proof." That sounds like what most of these products are, so why don't they just use that? I don't know. Maybe it's too on-the-nose. For the specialty classification, "a statement of the classes and types of distilled spirits used in the manufacture thereof shall be deemed a sufficient statement of composition."

The American whiskey category's three biggest brands, Jack Daniel's, Jim Beam and Evan Williams, all have multiple flavored expressions. Canada's Crown Royal is also in the act. And don't forget Sazerac's Fireball. All of them are flavored whiskey to you and me, but not to TTB.

So, while the sticklers will stickle, we know what is meant by flavored whiskey, which since Tennessee Fire was launched in 2011, has grown into a 10 million case business.

4 comments:

  1. A person knowledgeable in such matters has pointed out to me another advantage of using either the liqueur designation or specialty with a liqueur as an ingredient. With a few exceptions, liqueurs don't have to list their ingredients. Liqueurs can get some of their alcohol content from wine, which is taxed at a lower rate than spirit, thereby lowering the product's production cost.

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  2. It might also have something to do with the word "natural" flavors in the Whiskey designation. I suspect many of the flavor ingredients used in the for the others are not "natural", but artificial chemical flavor ingredients.

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  3. We wanted to make a peach-flavored rye whiskey (made simply by stuffing peaches into a barrel of rye whiskey), and the back-and-forth trying to get a label approved amazed me. The closest we could get was a Fanciful Name, with a description of Rye Whiskey with Natural Flavors Added which wasn't great as it we couldn't say peaches we had to say natural flavors... With a little bit of jockeying we ended up in the Rock & Rye category, as Peach Rock & Rye. Unfortunately the label approval process is always a dice roll for who you get and what they chose to focus on.

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  4. It occurs to me that: 1. if I am going to "flavor" whiskey with something strong and overpowering, then I might as well use cheap low end whiskey, because nobody will sense that. But then.. 2. since nobody will sense that anyway AND even cheap young whiskey likely costs more than NGS, then by calling something a liqueur "with" whiskey I can hypothetically use 1% of actual whiskey and everything else be based on NGS or wine as someone observed above.

    I don't think too highly of "mixology" but the few cocktails or long drinks that I do like (mojito, margarita, tequila sunrise, gin tonic, etc.) - I would much rather mix my own fresh and quality ingredients than buy a premade bottle.

    Seems like these are all non-matters to any serious whisk(e)y drinker :)

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