About two years ago we showed spirits in the form of whipped cream. Last year we showed spirits in the form of an ice pop (more commonly known as a popsicle).
Just last week we showed various chocolate wines, to underscore the movement toward “The Dessertification of Beverages.” Nathan added a comment, asking how long until a convergence between spirits and ice cream. Within the same week, TTB approved a line of ice cream products, with about as much alcohol content as a light beer. snoBaR is made by Brothers International Desserts, of Irvine, California. Brothers seems to be mainly an ice cream company, more than a spirits company. So far, Brothers has approvals for Pink Squirrel (with brandy and amaretto, as above), Grasshopper (with brandy and creme de menthe), and Brandy Alexander (with brandy and creme de cocoa). All of them are about 4% alc./vol. — a fair amount more than the rum raisin ice creams of an earlier era. Baskin-Robbins tends to suggest that their Rum Raisin is made with little if any rum, while Häagen-Dazs suggests that at least a little rum is used.
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The Dessertification of Beverages (aka The ChocoVine Sensation)
Congratulations to Clever Imports for propelling ChocoVine into one of the biggest trends across wine and spirits in recent years. The brand seems to be growing at well over 100% per year, and at about 1 million cases per year, may just be getting going, in view of the recent deal with The Wine Group. ChocoVine is wine with chocolate and cream; it is produced in Holland by DeKuyper.
At first, many people spoke snidely of ChocoVine, suggesting that grape wine is not the best match with chocolate flavors. But, to a large extent, this condescension has been overshadowed by admiration, purchasing, and emulators. Chocolais is one example of a chocolate flavored wine that has hastened down the path cleared by Steve Katz at Clever. But there are well more than a handful of other, substantially similar examples, such as this one. TTB approved the first ChocoVine label in 2007. Three years later, TTB approved the first Chocolais label and the first Choco Noir label, both in November of 2010.
A bit further afield from ChocoVine, hundreds of other examples continue to accrue, further showing tremendous momentum behind a trend toward the dessertification of beverages. Here we have Pineapple Upside Down Cake Liqueur, various alcohol infused whipped creams, and cupcake flavored vodka. Let us know of other examples and what you think.
Streamlining COLAs?
It may be safe to put away that gnarly old ruler, from fifth grade. A few days ago, TTB announced that it will ease up on scrutinizing your cpi’s and mm’s. At first this sounds like a good thing, and the “streamlining” as described — because many are the frustrations about waiting on a coveted COLA — only to find it lying in the tatters of rejection, because of a few letters too big or too small.
Industry Circular 2011-04 says:
(TTB) will no longer examine labels to determine whether the images included in the applications meet the type size, characters per inch, and contrasting background requirements. As a result, TTB will no longer return applications for correction due to these issues. However, TTB reserves the right to review and return applications for these reasons when it deems necessary.
In some ways this may be good, especially if it speeds up the system and makes TTB more efficient. But the main effect may be a shift of this not so trivial burden over to the applicant. There is no change to the various CFR rules requiring all your cpi’s and mm’s to be just right, and this Circular in no way mitigates that burden. In fact, TTB hastens to add: “The responsible industry member has always been obligated to ensure proper labeling for their products. In order to remind industry members of their continued responsibility for compliance, TTB will now include a qualification statement on all COLAs consistent with the purpose of this circular.” A real-world and early example is here (see just below the signature). If you think it’s not fun to get a “needs correction” notice after a few weeks, saying a few letters are too small — compare it to the pain of being told the same after you shipped a few hundred thousand cases.
There is no shortage of changes at TTB in recent months. In addition to all the changes noted here and above, TTB also brought back (a somewhat more limited form of) label expedites a few days ago.
Caricatures
Holy smokes, change really is afoot at TTB. I was startled to see these wine labels recently, with various and sundry famous politicians emblazoned all upon them, and not in the most flattering light. I suppose there is some extra latitude for parody- or caricature-type speech, and there certainly is or ought to be latitude as to political speech. But often in the past, TTB has disallowed presidentially-oriented labels. Just two years ago, the line was drawn here, as to President Obama, and this one seemed to go too far.
The abstraction, in these caricatures, seems to help, as does the absence of the full names. The Horizon Cellars Winery, of Siler City, North Carolina has a large series of the labels depicted above. We already pointed to various labels with Former President George Bush and Sarah Palin in the past, so today we elected to highlight Former Vice President Dick Cheney, President Barack Obama, Vice President Joe Biden, and Former President Bill Clinton.
But there are other reasons to revel in these labels. Any discussion of Joe Biden would be embarrassingly remiss without a fond recollection of that storied day when Joe Biden washed his Trans Am, in cutoffs and no shirt, out back behind the White House.
Age Range on Wines
This Malvira red wine happens to mention that the Barbera d’Alba blend is “aged in French Oak barriques … for 18-24 months.” Is there anything so troublesome about that? Maybe so. On a similar label (with a different age range), the above rejection shows that TTB would prefer that wine labels show the actual amount of age, rather than a range or guesstimate.
TTB did not cite any specific authority in the rejection above, but 27 CFR 4.38(f) would make it hard for the importer to win this argument. It says:
(f) Additional information on labels. Labels may contain information other than the mandatory label information … if such information complies with the requirements … and does not conflict with, nor in any manner qualify statements required by this part. In addition, information which is truthful, accurate, and specific, and which is neither disparaging nor misleading may appear on wine labels.
The stated range (six months on one and two months on the other) may be accurate and non-disparaging, but it’s not especially specific.
Santa's Elixir
Most people assume TTB would be okay with the second word but not the first. Actually, it’s the other way around. The federal government is okay with Santa, but is not fond of his elixir.
TTB asserts, from time to time as the issue arises, that the term “elixir” ought not to be allowed, because it would tend to suggest that the alcohol beverage has medicinal properties. That’s a big no no.
Good old Webster does not really disagree, and defines the term as: “a substance held capable of prolonging life indefinitely.” Hence there are very few “elixir” approvals after about 1999.
We don’t normally show the whole paper COLA in the space above. But the paper COLAs are getting fewer and fewer, as the bulk of labels are submitted via COLAs Online. The above is starting to look like a fondly remembered antique. This 1999 approval, for Santa’s Elixir wine specialty, is one of the oldest readily available in TTB’s Public COLA Registry, because it starts showing images in about 1999. Adding to this approval’s old school quaintness, I believe I see indications of a typewriter, a Xerox machine, and perhaps there is some Wite-Out lurking in the shadows.
I am writing this about a week before Christmas, but now that we’ve established that Santa will be okay, let me take this opportunity to wish happy holidays to Margie, Corianna, Sydney, Inci, Marguerite, Monica, Gary, Dave, Brittany, Keenan, John, Jaycee, Alyson, Jon, Meralyn, Vince and all friends of the firm far and wide.
