As to risqué alcohol beverage labels, there is no end in sight.
On the left is Rumpmeister Liqueur, made by Colorado Pure Distilling, in Lakewood, Colorado.
On the right is Snowbunny Ale, made by Hub City Brewing Company, in Stanley, Iowa.
If TTB will approve a shorter dress, we’ll . . . be surprised.
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Bemdesor and Bod Liqbt
These brand names don’t exactly roll off your tongue. That won’t stop Anheuser-Busch from bringing them to a TV near you. Keep your eyes peeled for these malt beverage products on TV and in the movies.
A few days ago, The Beersage raised good questions about these labels. At first it was not at all clear, but after some looking around, a good reason comes into focus.
This year’s approval for Bemdesor does not shed much light, nor does this year’s approval for Bod Liqbt. Go back a few more years, however, and it becomes clear. This 2006 approval for the mellifluous Bemdesor Seqyct quite clearly states:
THIS LABEL IS BEING USED FOR DISPLAY IN MOVIE/TV PROGRAMS ONLY. THE BOTTLE WILL BE FILLED WITH A NON-ALCOHOL PRODUCT IN ORDER TO COMPLY WITH FCC REQUIREMENTS.
A-B has used labels of this sort since at least as far back as 2003; here is an early Bod and here is an early Bemdesor. So far there is no sign of the FCC rule at issue, and it’s not the rule cited here. TTB does require something similar at 27 CFR § 7.54(b)(2): “Any label depicted on a bottle in an advertisement shall be a reproduction of an approved label.” Here are ten famous product placements for beer (with nary a mention of Bemdesor).
The Voyant Saga
Here is Bacmar’s use-up approval for Voyant Liqueur. It almost single-handedly proves it is not a good idea to print labels prior to TTB label approval. It looks painful and seems to have consumed a good part of Mr. Back’s spring and summer, from the April 2009 date of application until approval in July of the same year. The approval in all its fullness and glory, is here.
In decades past, it was relatively easy to get “use-ups” (aka temporary approvals). But it seems to be getting harder and harder. In the 1990s it was a simple matter of asking, face to face. Now it can easily take more time, money and resources than the forlorn product is worth. The Voyant approval probably shows how hard it can be. On the other extreme, this Skyy approval tends to show how quickly it can go, and then Jumbie is somewhere in the middle.
TTB’s main use-up policy is here. We like to think we’ve helped many companies avoid a Back-breaking struggle with TTB. In some situations, though, it can be difficult to avoid.
Ingredient Labeling on Wine
Back in the 1970s ATF/TTB worked vigorously to control wine-labeling, where FDA wanted to get involved and insist upon detailed ingredient lists, as is common on most other food labels. The matter got resolved by way of Brown-Forman Distillers Corp. v. Mathews, 435 F. Supp. 5 (W.D. Ky. 1976).
But this did not stop Bonny Doon Winery. Many of Bonny Doon’s labels include quite detailed ingredient labeling, and Bonny Doon has been one of few alcohol beverage companies willing to swim against the tide and volunteer this information. Bonny Doon’s Cunning label shows the following ingredients: grapes, tartaric acid and sulfur dioxide. It goes on to say the product was made with cultured yeast, yeast nutrients, French oak chips, and French oak barrels.
According to Decanter, Bonny Doon president Randall Grahm said:
It’s useful to provide more detailed information about the ingredients used in wine production and reduce our dependence on standard wine additions, even those considered to be benign such as tartaric acid, bentonite, yeast nutrients, enzymes, sulphur dioxide.
Let us know if you see other TTB labels with detailed ingredient labeling.
Soviet-Style Flag Over NH Capitol
You can probably find some examples of American flags on TTB labels. But TTB usually does not allow it, and for that reason you won’t find one on this label.
Manchester Brewing explains:
The feds forced us to remove part of the American flag, and replace the stars with a hammer and sickle. It’s the law, doesn’t have to make any sense. Originally, the Kombat ale was a Special Bitter, but it’s moved a bit beyond that.
A better view of the modified flag is here. Is it any wonder that TTB rejected a bunch of Manchester’s labels? Manchester goes on to explain:
Smacked Down by The Man! The TTB rejected all of our labels! One had a flag over the capitol; it was an American flag but that’s not allowed — so we put a Hammer and Sickle where the stars go, and that’s ok. Also, we used OMFG! on another label, and the government decided that was obscene, even though we protested that it meant Oh My Fairy Godmother and told them we were sticking to that story. So now it says “Censored” over the OMFG, and people tell me they find that funnier.
California Rum
Most of the world’s rum is produced in the Caribbean. Not a lot has been made in the US.
But lately there are signs of incipient production in California. Here are two: Agua Libre and Eurydice. Both are made by St. George Spirits in Alameda, California. A Swedish blog explains:
Eurydice starts with the fresh-pressed cane juice of 100% California-grown sugar cane. The cane, grown in Southern California, is harvested and crushed at St George Spirits’ Alameda facility where it is fermented with two strains of wine yeast designed to accent the fruit and floral notes of the cane.
It is good to see that TTB is not asserting that an appellation may not be indicated. On some occasions TTB has asserted that vintage-, varietal-, and appellation-type claims should not be made on distilled spirits products because these subtle characteristics are not discernible after distillation.