policy

This approval shows a tremendous amount of change in eight short years. First of all, it is hard to imagine that the Bureau would ever allow the term “vodka” on a beer label. Somehow I don’t think that would fly in this day and age. Further, the qualification seems to mandate the use of this term, in a particular way. The qualification suggests that the arrangement of the words may lead to controversy, rather than the reference to vodka and a famous vodka brand on a beer label. Pages 12-22 of this document show the controversy. Second, the product is gone. So is the named agency (that is, the label functions have moved from ATF to TTB). So is the person that approved it. Judy was tremendously helpful and probably had many good reasons to approve this label, in a different era. I wouldn’t want to mention the person, but for the fact that the name is right there and the memories are good. This is also a good example of a “use-up.” The approval tends to say the label is not ideal but the agency will allow it to be used for six months only. I believe TTB/ATF has allowed use-ups for many, many decades. It is difficult to imagine other agencies allowing this privilege, such...

On many labels, it can be difficult to draw the line. For example, it is tough to say whether this PimpnHo label (also by Weibel) goes too far. But then again, it is fairly clear that Champortini went quite a bit too far. It suggests Champagne but does not qualify to be labeled as Champagne. It suggests Port but does not qualify as Port. It sounds a lot like martini, but has none of the traditional martini ingredients. This puts the brand out in some rough waters, without the safe harbor of an approval before the crucial 2006 grandfather date set forth here. Any one of these issues might have been enough to sink this brand, but putting all these issues together, it would be a great surprise if the brand did not sink. It apparently lasted from April 27, 2007 (the date of the first approval) until a little after February 20, 2008 (the date of the third and final approval, as above). There is no trace of this brand’s survival at the Champortini website shown on the label.

Fernet-Branca has been well known around the world as a “digestiv” since about 1845. The above poster shows Fernet-Branca described as a “digestivo.” By contrast, the US label, on the right, bears no reference to this key term. TTB does not allow any reference to digestif, digestiv or similar. Here is an example of a recent rejection, wherein TTB explains that the term is not allowed, and why. TTB regards it as a therapeutic claim. Eric Asimov explains:

Digestives were historically intended as palliatives, meant to counter all sorts of ailments and physical imbalances. They may no longer be assigned quite the same medicinal value today as they were a few hundred years ago, but count me among the many who believe they can help to settle that queasy feeling.

Fernet-Branca is one of the more famous examples of a digestif, but there are others, such as Fernet Stock, Escorial, Becherovka, Averna, bitters, amaro, etc. In general, digestifs are intended to be consumed after a meal, with dessert of coffee. By contrast, aperitifs, such as Aperol and Campari, are most often served before meals.