modernization

TTB proposed to modernize the beer, wine and spirits labeling rules in late 2018, in a sweeping 132 page document. I thought it may be useful to take one narrow provision at a time, and compare the old version to the new, proposed version. Today I will look at the long-time restriction on describing spirits as “pure.”

The old version of the rule is at left, above. It’s been in place for many decades at least. The new version is at right.

I would have expected to see some changes because the rule has always seemed a tad random. It is hard to understand what the government should have against this thoroughly ordinary word. It is especially peculiar when we consider that the rules (old or new) take no issue with describing a beer or wine as pure, yet shudder at the prospect of describing spirits in such terms. Another reason to look for changes in this rule is because TTB and ATF have struggled with it time and again since the 1930s. In 2005, TTB proposed to modify the rule; the 2005 notice explained that the government first published a rule on pure in April of 1936, then had hearings in May of 1936, then reconsidered the issue in November of 1978 and December...