Has anyone tried these and lived to tell about it? Some people prefer the organic or biodynamic, Others, apparently, lean toward the toxic or deadly. It is nice to see TTB giving consumers some credit for being able to put things in context, and for recognizing that nobody will force them to buy either one of these products (unlike, say, health insurance or government).
Toxic Sludge is an ale made by Blue Point Brewing Company of Patchogue, New York. Jersey’s Toxic Waste, by contrast, is a distilled spirits specialty made by Strong Spirits, Inc., along with Line Brands of Long Branch, New Jersey. Michael Kanbar, of Strong, explains that Strong Spirits “is a contract bottling facility located in Bardstown, Kentucky, ‘The Distilling Capital of the World,’ and does both small and large runs and can handle specialty packaging projects.”
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Personalized Labels
TTB has recently liberalized the treatment of personalized labels, such as a wine label with “Happy Birthday Bob.” No longer will it be necessary to burden your company, or the government, with paperwork to cover “Happy Birthday Steve” or Judy, Tom, etc.
TTB announced this change on September 21, 2011 in TTB Guidance 2011-5. The document supersedes a policy from about a year and a half earlier; the 2010 policy required a new approval for just about every variation (such as each wedding, retirement, Bar Mitzvah, graduation, anniversary, etc.). In liberalizing the policy, TTB said:
Our 2010-1 guidance did not allow certificate holders to change the artwork or graphics on personalized labels without resubmission of the labels for approval. We have reconsidered this requirement and now permit certificate holders to make changes to the graphics or artwork on a previously approved personalized label without having to apply for a new certificate of label approval.
The above label, from Llano Estacado Winery, is an early approval under the new policy. The new policy seems due at least in part to pressure from Sen. Schumer. He mounted a vigorous campaign, on this topic, over the past summer. His August 9, 2011 press release, noting the progress, said:
In the case of … personalized labels the TTB agreed with Schumer’s request to streamline the process saying, “Effective immediately, TTB will not require resubmission of labels due to changes in graphics or artwork.” In the past, TTB permitted wineries to simply apply once for approval of a custom label template to ensure it contained the required regulatory and safety warnings, after which the winery could customize and personalize the artwork … to suit the specific event. TTB then changed course to require individual approval of labels when changes were made to graphics and label components apart of the regulatory and safety warnings. By working with industry stakeholders to find ways to streamline approval of these custom labels TTB could, in turn, help ease the current backlog of COLA applications.
The press release also noted:
New York wineries have recently reported that it can take at least one month to receive approval of an electronically-filed COLA application and two to three months for a paper application. Often, when wineries finally do receive feedback, it is with a rejected label and the necessary corrections, and at that point labels must be resubmitted and the COLA process must begin again. The TTB told Schumer itself that they have noticed a significant increase in the typical amount of time it takes for them to respond to requests for label approvals.
So far, it does not seem that the current personalization policy would extend all the way to other masses of labels, such as Molson and Twisted Tea (large numbers of labels with other sorts of small variations).
Founding Fathers Beer
Part of the challenge and complexity is that label rules and trends change often. As recently as a few years ago, TTB would balk about pre-eminently famous people, such as these, on alcohol beverage labels. Founding Fathers Beer is bottled by CBC Latrobe in Latrobe, Pennsylvania. I tend to doubt that TTB would allow a President Obama label, even today (except maybe as a caricature), but George Bush, Bill Clinton and the prior Presidents may well be fair game now or soon.
Make Your Own Spirits
It’s clearly okay to go home, add some tomato juice to your vodka, and call it a bloody mary. And it’s almost certainly a bad idea to go home and fire up your small pot still, to make just a little spirits.
Somewhere in the middle, we now have “High Proof Micro-Batch Distilled Neutral Spirit Designed for Infusing.” It comes in a 375 ml. bottle, at 160 proof. It is made by The Northern Maine Distilling Company, of Houlton, Maine. The first related approval seems to go back about one year. It mentions that the vodka is designed for “infusions, extractions, mixology, and culinary applications.” The information-packed website explains:
160 Proof? Yikes! Don’t freak over the proof! The high concentration of alcohol makes Twenty 2 HPS perfect for infusing fruits, vegetables, meats, or dairy into vibrant liqueurs or flavored vodkas. Think of the 160 Proof like a very sharp knife in your kitchen. If you handle the knife with respect, it can perform amazing tasks. Same with the High Proof Spirit. It’s “sharp blade” creates infusions in hours, not weeks.
We think Northern’s COLA is interesting because we don’t know of too many other products designed for this manner of use. Also, the label underscores that TTB has no problem with strength claims on certain spirits products. This one has “High Proof” in big letters. Plenty of other labels have “Overproof.”
The site has many copyrighted recipes, such as “The Dude’s Caucasian,” inspired by Jeff Bridges and The Big Lebowski. Other eye-opening recipes include:
- Smoked Gouda Infused Vodka
- Caramelized Red Onion Infused Vodka
- Failed Recipes such as Bacon Infused Vodka (“One of the simple rules of this game, like distilling, is ‘junk in = junk out.'” “These are not soy based Bacos, but actual real bacon pieces packed with preservatives so that they don’t need to be refrigerated. Yum? Maybe on a salad, but not in an infusion.” “The flavor was of bacon, but not pleasant. It just wasn’t good.”)
I spent a fair amount of time trying to figure out why Twenty 2 as a brand name. I assumed it had something to do with the consumer’s age, such that, e.g., 7 Teen would not be a good choice. The answer was not evident on the company’s website but may be here:
originally, the name for the vodka was Jewell Vodka. But a company out West already had a copyright [trademark?] on that name, so it was back to the drawing board. The couple decided to get a bit more abstract. … “We talked about doing Aroostook Vodka or Katahdin Vodka, but those are so obvious. We figured, let’s pick a word that can be freely associated with anything,” said Galbiati. “Twenty 2 could be anything. It could be your address, your birthday, a sports jersey. It can mean anything to anyone. It sticks in your mind. Plus, the alliteration is nice. A Twenty 2 and tonic sounds good.”
The same Bangor Daily News article also explains, about the owners and startup:
Starting in early 2006, Galbiati and Jewell quit their jobs and began the process of starting up their business. While getting a license for a winery or brewery is, relatively speaking, not uncommon, getting the license for a distillery is a much more involved process. According to federal law, a person can brew up to 100 gallons of beer on their own, or 200 gallons if two adults are present in a household. A person also can make up to 5 gallons of wine. Any more than those amounts, and a license is needed. … A person cannot under any circumstances distill any amount of spirits without a license. It took Galbiati and Jewell about three years to get the OK to start making Twenty 2.
When I first saw the 2011 approval, I was concerned about blowing Twenty 2’s cover, before they were ready, in that the COLA is only a few days old. But they are clearly ready. Of course they have the 2010 COLA, along the same lines, and the 2011 COLA is a public record — but also, Northern has a big website with a lot of information about this idea (plus Twitter and Facebook). On this topic, I will take this opportunity to reconfirm that we have no real interest in publicizing anyone’s news, before they are ready. We make no claim to be journalists. We will be especially careful not to publicize any client news, before the client is good and ready. In the case of non-clients, we may ask, or be guided by generally available information (or the absence thereof). If, as here, the company website has a lot of the same information, it becomes difficult to ascertain what could be sensitive about the COLA.
Cougars on Facebook
Clos Lachance has two fairly new wines. CougarJuice and MommyJuice.
In the matter of lusty cougars, Peyton Imports was fairly early, with the Urban Cougar. Perhaps she is real, what with this site exhorting over a million members to: “Join CougarLife.com and meet great young guys before they’re snatched up.” Foreshadowing that this theme may be over-ripe, or ripe for a trademark lawsuit, Cougar Juice Vodka slinked into the bar a few months ago.
The MommyJuice label also happens to mention Facebook on the back label, prompting TTB to assert that “Information on Facebook and/or Twitter must be in compliance with all labeling and advertising regulations.”
Sen. Schumer Says Labels Take Too Long
Sen. Charles Schumer spoke at a Finger Lakes winery late last week and said many wine labels take too long to get approved. He was especially concerned about labels submitted to TTB by New York’s more than 300 wineries. MPNnow.com reported:
the delays — sometimes up to three months — result in wineries not being able to market their wines. The Washington, D.C., agency’s staff has been shaved by budget cutbacks over the last decade while the tide of label-approval applications from wineries nationwide almost doubled from 69,000 in 1999 to 132,500 in 2010, said spokesman Tom Hogue. “And that doesn’t take into account any of the time going back and forth with applicants to make sure labels they’ve submitted actually meet the legal requirements,” Hogue said.
John Martini, co-owner of Anthony Road Wine Co. said:
label approval used to take a week. One label he submitted online May 12 was approved June 15, but he said he has heard horror stories of approvals taking 75 to 90 days. He said new wineries often have long delays because their labels don’t meet the specifics of the label law, which was approved after Prohibition ended. However, he said, “Every winery has a goofy TTB label story.”
The Senator’s press release, and letter to TTB, are here. Key points are:
- Many New York wineries have received rejected labels from TTB with a request to correct one issue, only to make that change and receive notification of a new correction. This creates a back and forth or ping-pong effect that can result in weeks of backlogs and headaches for these wineries, and prevents bottles from hitting the shelves. Schumer asks that the TTB clearly identify all of the issues that need to be addressed on the first rejection.
- Now New York wineries are reporting it can take at least one month to receive approval of an electronically-filed COLA application and two months for a paper application. It takes even longer in the event TTB rejects a label and it must be corrected and resubmitted to re-start the COLA process.
- For new wineries, the effect can be devastating as one winery reported waiting almost a year for label approvals which nearly kept them from opening for business this year.
- Wine industry experts estimate that as many as 10% of the labels waiting in the application process are personalized labels produced to commemorate special events like weddings and birthdays. In the past, TTB permitted wineries to simply apply once for approval of a template to ensure it contained the required regulatory and safety warnings, after which the winery could personalize the artwork on the front of the labels to suit the specific event. TTB now requires individual approval as the labels are changed to suit the occasion.
I would like to see more news about the one that took almost a year. While Sen. Schumer makes some good points it is something of a platitude to say TTB needs to handle far more than 100,000 labels per year quicker, with fewer mistakes, and with fewer people. He does not propose much by way of specific solutions. The suggestions about personalization (as at point 4 above) are not a cure-all because TTB does allow some personalization as here, and TTB probably never allowed one template approval to cover more than one brand, type or appellation.