Under the new and important Food Safety Modernization Act (FSMA), FDA was supposed to commence food facility re-registrations yesterday. This was mandated by section 102 of the FSMA law, enacted in 2011. This piece of the FSMA puzzle is not off to a propitious start. It was bad enough that there was not much guidance or clarity about how this would work, before the October 1, 2012 to December 31, 2012 re-registration period began. But it’s even worse that the brief window for required and biennial re-registration began yesterday — and yet there is still no means by which to accomplish what is required. The renewal website was briefly available last week, for a few hours, then it froze, then it disappeared, to be replaced with an oh so calm assurance that:

Biennial Registration Renewal for Food Facilities will not be available on October 1, 2012.  We therefore will not be accepting food facility registration renewals at this time.

Natural Products Insider has explained:

FDA is delaying the registration renewals that are mandated under a 2011 law after the Grocery Manufacturers Association and numerous other trade associations recently sought guidance in meeting the registration requirements. “It would be extremely inefficient and costly for companies to re-register shortly after October 1st based on the...

Here is Pumpkin Face Dominican Rum. Does it remind me that summer is ending and Halloween is around the corner? No. It reminds me of many other things.

It reminds me that Dan Matauch at Flowdesign has a lot of skill. I especially like the main font.

It reminds me that Mark Itskovitz was serious when he said he was thinking about getting into the spirits business.

It reminds me of the new distiller and former bartender, I met at the ADI conference — at the bar — who said bartenders hate shapes like this because they take a lot of space. But they never go in the trash can.

It reminds me of the Apple-Samsung litigation. If Apple designed this, one might expect Apple to claim a patent on certain orb-shaped decanters.

Finally, it reminds me to thank Ann and Gerard for stopping by yesterday and saying nice things about this blog. Gerard is one of the most famous chefs in the U.S., and Ann makes a pretty good veal dish herself.

Q: What do you call spirits distilled from beer? A: Not “Spirits Distilled from Beer.”

Every now and then we see a “Bierschnapps” or a “spirit distilled from beer.” But even though beer is the main ingredient, most of the U.S. approvals seem to avoid any reference to “beer” or “bier.” It seems that TTB is not in favor of spirits labels that refer to beer. In the above example, Woodstone Microspirit seems to be, pretty much, just spirits distilled from beer. Even though the producer probably wanted to describe it as “bierschnapps” on the label, the main description is “Spirits Distilled from Grain and Hops.” The producer, back in 2008, set forth his frustrations here:

Beer Schnapps as a label has not been approved by the TTB for 4 months 3 tries and counting, the formula from the local microbrewery was accepted on the 2nd time through.  Its been over 2 years so far and it is fighting me every step of the way. … We are now re-submitting the product with a fanciful name and not calling the product beer schnapps at all.

TTB seems to have allowed a reference to ale but not beer. Classick is another example of a bierschnapps. I have not been able to...

In early July TTB announced a massive and important change to the COLA system. TTB greatly expanded the “Allowable Revisions to Approved Labels” (hereinafter “ARTAL,” as on page 3 of the new 4-page COLA form). TTB began laying the groundwork for big “streamlining” changes in early 2012, as summarized here. Although some of the ideas seemed very modest as of then, the streamlining train clearly picked up momentum in the next few months. It seems entirely possible that some of the new changes could or should cut a very large percentage of the more than 10,000 labels submitted to TTB every month. Compared to a few years ago, it is quite amazing that the lighthouse label on the left (above) could change to something as different-looking as the striped label on the right — without any need for a new COLA. The TTB ID number on this label, for example, shows that TTB received at least 671 label applications on just one day in April 2012 — to say nothing about the labels submitted via paper. That should not happen anymore. Instead, applicants should get familiar with ARTAL. It can eliminate lots of waiting, expense, frustration, inconsistent determinations, TTB work and applicant work. In my view, the biggest changes to ARTAL are these....