policy

Moscato is so very popular it can no longer stay contained within the wine context. Here it is — in a liqueur. The product is Courvoisier Gold – Cognac & Moscato. It is classified as a liqueur, made in France, and imported by Jim Beam. This seems like an important approval because it was not so very long ago that TTB/ATF frowned upon varietal terms — when used on spirits labels — and even when the spirit was made almost entirely from the named grape. For example, it was very common in the 1990s for ATF to say that varietal terms should not be shown, or should not be prominent, on grappa labels, because varietal characteristics are subtle and are not likely to survive past distillation. It looks like it took Beam many months to get this approval. The application went in on March 5, 2012 and did not get approved until more than three months later. It must be a pretty special grape if it’s the subject of not only a bunch of rap songs, but also a few memes:  problem, freshman, classy, cat.

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....

The highly secretive and powerful Triple Sec lobby has struck again — this time to require at least one drop of triple sec in certain alcohol beverages. Google it as much as you wish, and you will find little about this uber-secret institution, rumored to have strong ties leading all the way back to France. That’s because it’s secret. Some even say that Sen. John Kerry, with his thinly disguised sympathies for many things French, is Triple Sec’s man in Washington. On a more serious note, for many years, TTB has required at least some triple sec in products that purport to be margaritas. The policy is here, at page 13 (scroll down to Margarita). The policy is in TTB’s “Beverage Alcohol Manual” for spirits. The BAM can be a handy resource to explain and supplement the regulations. Sometimes, as here, it goes considerably beyond what the law or regulations say. In this particular case, it seeks to mandate that every margarita must have:  “Tequila, triple sec and lime or lemon juice or oil or natural lime or lemon flavor.” Here is a recent example of TTB seeking to enforce the rule. Does such a rule make any sense in this day and age of scarce resources? What is the worst that...