Shanken News Daily recently alerted us to Dogfish Noble Rot. It is:

a wine/beer hybrid that combines traditional barley, hops, water and yeast with winegrapes. Named for the grape fungus botrytis, which is associated with Sauternes and Tokaji dessert wines, Noble Rot uses Viognier and Pinot Gris grapes sourced from Washington’s Alexandria Nicole Cellars. The 9%-abv offering will be available in about 27 states this week, priced at $13 a 750-ml.

The statement of composition on this product looks a bit redundant, with two references to grape must — but upon closer review it nicely underscores the distinction about adding the grape must before and after fermentation. I wonder if the must added before fermentation could or should be considered wine. Dogfish explains:

The first addition is unfermented juice, known as must, from viognier grapes that have been infected with a benevolent fungus called botrytis. This noble rot reduces the water content in the grapes while magnifying their sweetness and complexity. The second is pinot gris must intensified by a process called dropping fruit, where large clusters of grapes are clipped to amplify the quality of those left behind. “This is the absolute closest to equal meshing of the wine world and the...

TTB has been working on a new COLA form, with new and more flexible rules about what may change without seeking a new label approval. TTB announced this in the January 13, 2012 Newsletter and the Federal Register two weeks prior.

The new rules, if/when implemented, could allow a huge variety of big and small changes — without the need to submit, wait, haggle.

Here is the draft form. For example, the new rules (at page 3) would allow you to:

1. Move mandatory around. This is at category 2. This would allow you to move VODKA from the bottom of the front label to the top of the front label, for example. It would not allow you to move VODKA from the front to the back. (The draft form does not seem to make it clear, about whether it’s also okay to reposition non-mandatory. It would be very strange if okay to move the important stuff but not the less important stuff.)
2. Change colors. This is at category 3.
3. Add/delete/change a QR code. This is at category 22.
4. Add/delete/change social media icons. This is at category 25.
5. Add/delete/change information about awards. This is at category 26. It remains a bad idea to announce  “Award for most antioxidants in a Cabernet.”
...

Be careful about the five year rule as above and here. The rule says TTB formulas expire five years after approval. Not all formulas. Just the ones for imported products such as vodka, sake, and liqueur for example. This is in substantial contrast with TTB label approvals, permits, and domestic formulas. Generally speaking, they don’t expire unless the applicant changes something.

In our experience, TTB tends to explain the expiration date on the relevant formula approvals, but not in the regulations or widely elsewhere. An example is here. It can come as an unpleasant surprise, if you are seeking a new label approval more than five years after issuance of the formula approval, as in the case above. In the time period about 5-8 years ago, TTB would frequently allow a use-up in some cases where the formulas was expired. But, as suggested above, use-ups are much harder to get, in more recent years.

In recent months TTB has been busy tinkering with the label approval process. TTB announced the culmination of its streamlining efforts here. This is important for all regulated entities because, despite all these streamlining initiatives (plus the advent of computers and online filing), the average processing time for spirits has moved from a few hours to well over a month, during the past 20 years. Most spirits labels are currently taking well over 30 days, and TTB often says you should allow up to about 90 days. Since last summer, things seem a lot better with wine labels (moving from over a month to about half that). Beer has stayed relatively and consistently quick during the past several years, with an average turnaround of about a week.

In the late 1990s, if I recall correctly, it was possible to receive a label by fax, Scotch tape it to a form, Xerox it, walk it across the street to ATF, not go through a metal detector, wander around the government building until you found the label reviewer, wait your turn — and voila — walk out 45 minutes later with approval in hand. It was even possible to sit face-to-face with the reviewer and revise the application on the fly...

I have not spent a lot of time in Austin, Texas, but I like the slogan:  Keep Austin Weird. I am thinking about this today because, quite often, it occurs to me that the alcohol beverage industry, similarly, seems to draw more than its fair share of eccentrics. In my view, that’s a good thing and helps make it a fun place to spend a career. I am thinking about the distiller who lit his finger on fire in the office, to make sure we understand that his product is the real deal.  I am thinking about the client who owns a small island in the Caribbean, and once ditched his Rolls-Royce by the side of the road to sail around the world with a monkey. I am thinking about the Tequila importer who said 20 minutes was more than enough time to get across town, to our front section seats at Madison Square Garden, for Elton John’s 60th birthday concert.  (Little did I know that he’d park his big Mercedes at the adjacent curb and scurry up a back-alley entrance, midway through President Clinton’s introduction.)  I am also thinking about the beer executive who wore a green leisure suit, all day, on St. Patrick’s Day a while back. It would not be better, if...