...no, not that there's a new micro-distillery in Buffalo called the Black Squirrel Distillery, but that their nutty claim - that their distillate of maple syrup can be labelled "rum" (as promoted by the Shillery's resident expert, Mamajuana) - is either complete squirrel nuggets, or the degradation of "rum" is now complete.
Dig this:
http://buffalorising.com/2014/11/black- ... distilleryQuoting Jason Schwinger of Black Squirrel:
“The reason for rum is that nobody is doing it. NY State law designates us with a Class D Farm Distillery License. That means that we must make our spirits with a minimum of 75% NYS farm ingredients. That’s easy for whiskeys and cideries, but there is no sugar being produced in NYS. That makes it hard to produce rum. So we decided to use maple trees instead.
The problem was, the US Tariff and Taxation Bureau (TTB) is in charge of dictating what your spirit can be called (what it actually is), and there was no designation for rum made from maple syrup. Fortunately, we were able to obtain TTB formula classification as rum with label approval.
Now, instead of using press sugar cane juice and molasses, we are the first modern day distillery to make rum out of maple syrup – it’s going to be a traditional amber rum style. It’s new to New York State and created by Black Squirrel.”
Now either the TTB is now willing to completely ignore their own Standards of Identity - or - the distiller misunderstands the application process - or - they have yet to get actual label approval - or - they are applying not for "rum" as we know it, but as a "fanciful" spirit (a spirit of such uniqueness that there exist no common industry or consumer understanding.
So how does it work?
The process works something like this: the first step is to get "formula approval" which is exactly what it sounds like. First you consult the pre-COLA test/form to see what forms and/or, analysis you may need based on the product type.
http://www.ttb.gov/industry_circulars/a ... pirits.pdf
In almost all cases you will need to submit a "formula" form TTB F 5100.51, for pre-approval by the TTB. The formula must include a detailed and specific quantitative list of each and every ingredient in the product, and a detailed description of the entire production process. At a minimum it must include:
- 1. Information on the agricultural source of alcohol for any distilled spirits used in the product;
2.The percentage of alcohol by volume/proof at distillation of any distilled spirits used in the product;
3. Identification and source of any flavoring material used in the product;
4. A specific description of when flavoring material is added in the production of the product; and
5. The total volume and alcohol content of the finished product.
It appears the Fuzzy Tail Boyz have gotten at least pre-approval.
The next step is "label approval" and this is where things get more specific. According to section §5.32 Mandatory label information:
- (1) Brand name.
(2) Class and type, in accordance with §5.35.
(3) Alcoholic content, in accordance with §5.37.
Thus "Rum" MUST be made from sugar cane or one of its direct by-products (eg cane syrup, molasses). NO EXCEPTIONS!"(f) Class 6; rum. “Rum” is an alcoholic distillate from the fermented juice of sugar cane, sugar cane syrup, sugar cane molasses, or other sugar cane by-products, produced at less than 190° proof in such manner that the distillate possesses the taste, aroma, and characteristics generally attributed to rum, and bottled at not less than 80° proof; and also includes mixtures solely of such distillates."
So how can maple distillate be labeled?
That would be as a specialty spirits, NOT already defined in section §5.22 (above). Clearly, a spirit made from maple syrup has not ever been defined. According to §5.25, these special, unusual or what the TTB calls "fanciful" spirits MUST be labeled with "a distinctive or fanciful name, and... a truthful and adequate statement of composition."
Thus this maple distillate might be called "Maple Surprise" or "Pancake Dreams", "made from distilled Grade A Maple syrup". It can't even be called an "Imitation Rum" as this distillate fails even to meet that standard.
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http://www.ttb.gov/formulation/pre_cola.shtml
http://www.ttb.gov/forms/f510031.pdf
http://www.ecfr.gov/cgi-bin/text-idx?SI ... ain_02.tpl
