Labeling watchdog Wade Woodard discovered it and did an awesome detective job, getting both TTB and Wild Turkey parent Campari on the record about the label's questionable statement about ages. You really should read his account, which can be found here on his 'Tater-Talk' blog.
The gist: Since this whiskey is more than four years old, an age statement is not required. If, however, a statement about ages is made it must be truthful and in the standard form, which is "this whiskey is ____ years old," or one of several acceptable variations of that sentence. If the product contains whiskeys of different ages (as most do), its official age is the youngest liquid in the bottle, except that the age of each component whiskey can be given if the percentage of each is also stated.
Wild Turkey's wording, "...this iconic bourbon is perfectly aged for up to six to eight years...," would seem to be non-compliant, but Wild Turkey found a loophole. The rules provide that labels "not required to bear a statement of age ... may contain general inconspicuous age, maturity or similar representations without the label bearing an age statement.” By that analysis, Wild Turkey's statement about age isn't an age statement, it is an 'inconspicuous representation' about age.
When brands have made 'inconspicuous representations' about age in the past, it has been with phrases like 'fully matured' or 'extra aged.' They have eschewed numbers. Sneaking numbers in is the new trick Wild Turkey has pulled off.
Although all this may be legal, it rubs Woodard the wrong way. Me too. It tells you nothing. It is as if they put "this whiskey might be six to eight years old" on the label. They might as well say, "hey, it's possible some 8-year-old whiskey found its way into this bottle, but who the hell knows?" All you really know is what you already knew from the absence of an age statement, which is that the whiskey is least four years old. But many consumers will read it as the whiskey is between six and eight years old, even though it actually says no such thing. It is much like a trick Wild Turkey pulled about 25 years ago when it took the words '8 Years Old' off the label and replaced them with 'No 8 Brand.' Many others have used the same trick when they dropped their age statements.
One can also dispute the new label's claim that Wild Turkey bourbon has a 'high rye content.' The Wild Turkey bourbon mash bill is 75 percent corn, 13 percent rye and 12 percent barley malt. That is more rye than Jack Daniel's (8%) but less than Jim Beam (15%) and way less than Old Grand-Dad and Bulleit (each about 30%).
Since actor Matthew McConaughey is now Wild Turkey's 'Creative Director,' this probably is all his fault.
Love it.
ReplyDeleteUH OH... The statement “aged up to 6 to 8” years implies that the whiskey is in fact aged LESS than 6-8 years. That is dangerous wordplay. Consider: My age is "up to 80 years old." Or, my income is "up to one million dollars per year"
ReplyDeleteThis wordplay means that they could put in one year old whiskey :-/ (I doubt that they are doing this, at this point, but this sets a dangerous precedent.) The TTB needs new leadership
Nope. As Chuck makes clear, the standards for "straight bourbon" ensure that the contents are at least 4 years old.
DeleteAll bourbon is required to be age stated if less than 4 years old, not just straight bourbon.
Delete"Robert New England said...
ReplyDeleteUH OH...
This wordplay means that they could put in one year old whiskey :-/ ...."
I don't think so. It's still a no-age-statement straight bourbon, meaning it has to be at least four years old. Right, Chuck?
Yes. As labeled the youngest whiskey in the bottle must be at least four years old.
ReplyDeleteI would have more respect if a distiller stuck a 4year old age statement on the label. I would have more respect for that than a 7year old with no age statement. Just My Opinion.
ReplyDeleteI will add these shenanigans seem to come from the marketers rather than the distillers.
ReplyDelete
ReplyDeleteOther than pointing out potential label shenanigans, which indeed may have serious repercussions, the high point of having viewed this post is that it put me in touch with the Tater-Talk blog, all of what I've seen within I agree with. Thanks Chuck and Wade!
For me it means the age of the whiskies in the bottle can be anywhere between 4-8 yrs old, as it says "up to 6 to 8 yrs", not "From 6 to 8 yrs" . It has no age statement so we know that the youngest whiskey has to be at least 4 yrs old, but they are very clever in their non-statement to leave the possiblity of whiskey younger than 6 yrs old in the bottle.
ReplyDeleteThanks for posting this Chuck. I wasn't following Tater Talk, but now will. I posted a comment on Wade's blog. I will post below as a CC to you. Thanks again.
ReplyDeleteThis has been discussed several times on Reddit's r/bourbon - going back to when this 2015 label first saw use. Kudos to you for actually getting on the phone with the regulators to get to the bottom of it. While I don't think it's as misleading as the infamous "Old No. 8," its potential as a precedent is far worse and I think that's the takeaway here.
Do I believe Wild Turkey is trying to be deceptive? No. In fact, per several recent public comments by Bruce Russell, the latest batches of WT 101 contain 7-10 year old KSBW. I honestly think the Russells are striving for a better product everyday.
But I'll re-state: while I don't find this example particularly misleading, the potential here is far worse.
And thank you, Chuck, for addressing the "high rye" claim. I'm a 101 fan, but by no means would I consider it high rye evidenced in its lack of rye characteristics found in its taste and texture--much less a mashbill plainly showing how little is in there. Seems I read somewhere that 15% rye was the unwritten measure for high rye, but even that seems low compared to the really good and truly high-rye whiskeys you mentioned.
ReplyDeleteBeginning to distrust my favorite Gobble
ReplyDeleteI let the Bourbon in the bottle do the talking, not the label on the outside. That's just me.
ReplyDeleteI see where you’re coming from, though I’m reminded of Col. Taylor’s efforts. We have to trust the label. If not, welcome to the Wild West. I trust WT, but the precedent here is my main issue.
DeleteThis sort of mealy-mouthed marketing is why I have been buying only bottled-in-bond since the start of this year.
ReplyDeleteI like what we have now with the "Straight" rules. If a bourbon labeled as Straight with no aged statement then one can feel confident that at a minimum of 4 years old it has a good shot of being quaffable. We should not get too caught up in the numbers. A whiskey aged 5 years at the top of warehouse A can be better than a whiskey aged 6 or 7 years at the bottom of warehouse B. While a specific number can be a predictor, it does not offer a guarantee of superior quality.
ReplyDeleteI have to agree as well. Yes, I like WT101 and I am not deceived by the label. But it abuses my intelligence. "Up to 6-8" is logically meaningless. The whole point of "up to" is to stretch it upwards. Then just say "up to 8". It's like walking into a used car lot and the salesman asks: "how much are you looking to spend?". You tell them "2-4 thousand" and 30 minutes later you drive out in a shiny old $5k vehicle :)
ReplyDeleteTrusting the label sounds like a lofty goal. But it's the same as trusting people you've never met and have no continuous relationship with. Not feasible. I see a label like that, I chuckle (and shudder) and fall back on my own research and knowledge.
Besides that, sadly, as the Common Core(TM) generation comes of age, we'll see more of this, not less. "How old does this whisky feel or identifies as?" But it's nothing new. Remember commercials in the 90's: "more Americans buy a Ford than any other car"? I always thought to myself: "what does that even mean? More Americans than Germans buy a Ford? Or Americans buy more Fords than any other brand (is that even true)? As spoken the statement was meaningless. Too meaningless to be accused as being false :) That's the strategy - being so meaningless that it's not even wrong.
Next thing we know they'll introduce the Solera aging process to bourbon. And then lobby the feds to allow "average" age instead of minimum. Of course "up to 6-8" is even less than average :)