Being a Smart Aleck Cost Distiller Extra 1.5 Months with TTB Approval Process

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Sub Rosa Spirits is an Oregon craft distillery producing non-traditional distillates that carry great intensity and flavor. They also have quite an irreverent streak. Owner Michael Sherwood shared with us the story of their (rather amusing) TTB approval journey.

Sub Rosa Spirits makes two unique vodkas. One is flavored with fresh Oregon grown organic Tarragon. The other – a Saffron vodka, is a heady mélange of eight spices that gives a nod to India and Asia.

Sherwood said, “It took over two months to get our labels through the federal maze. They didn’t like my wording one bit. It seems it was a bit too mystic and medieval for them.”

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Examples of the Craft Spirits Labels Submitted to TTB

Proposed Wording on the Saffron Label
Sub Rosa Saffron Label

“By accepting this elixir, you are now part of the Cadre of Sub Rosa.”

Rejected: Elixirs are ancient medicinal formulas and can’t be used in reference to alcohol lest anyone think they can be cured by drinking. I guess they feared the cadre, the insiders who joined my cult, would either heal themselves or maybe just overthrow the government.

Compromise: “By accepting this spirit…” changed to “By accepting this bottle…”

They let the wording “Welcome to our fellowship of indulgence” pass with no objection. I guess hedonism is okay.

Proposed Wording on the Tarragon Label
Sub Rosa Tarragon Label

“Light notes of anise that are herbal and refreshing.”

Rejected: “Light” connotes light alcohol even though it was talking about a flavor. Can’t suggest distilled spirits in the context of strong or light. Guess they missed the 90 proof on the rest of the label. But Lite Beer is fine?

Rejected: “Refreshing.” You can’t use that in conjunction with distilled spirits. It’s a health claim! You can use “refreshing” on a beer label, but not a distillate. Who knew?

Proposed wording: “Behind the hidden doors of Sub Rosa lie hidden truths where ethanol alchemy and molecular gastronomy meet.”

Rejected: Alchemy is the ancient art of not only turning lead into gold, but also concocting medicinal formulas. Can’t use that, oh no.

Compromise: They finally accepted “ethanol divination” instead of alchemy, but that took them over two weeks to chew on. Thank god I didn’t claim you’d be clairvoyant too!

I also had to translate all foreign text used. There is Latin all over the place on the labels. The first two uses of Latin flew by with no hiccups:

Apparently Latin is OK
Sub Rosa Saffron and Tarragon Latin Icons

Sapre Aude—Dare to Think. Have courage to use your own intelligence.

Quaere verum—Seek the Truth

They have a problem with my use of the Olympic Games’ motto of “Citius, Altius, Fortius,” which is Latin for “Faster, Higher, Stronger.” I use this on the Saffron label and it remains as I designed it. The TTB let this one go, but had many discussions about it. No doubt they feared that the imbiber would think they could actually run faster, jump higher and be stronger by drinking the Saffron infused vodka. Alcohol does do strange things to people, or rather, people do strange things after drinking, so I guess that is a legitimate fear. At least they didn’t interpret it to mean that by drinking this “strong” 90 proof spirit you would get “higher, faster.”

Evidently there are 100 words you can’t use on a liquor label. They can’t tell you what they are unless you use them, then you know.

God forbid that anyone distilling alcohol has a sense of humor, much less a subversive bent. Pushing the boundaries of the TTB cost me an extra month and a half and no one got in on the “fun.” I should have had these products out by late August. Instead it was the first week of October 2007 by the time everything was printed and labeled. Being a smart-ass has a price. I pleaded my case and had to dumb down the text some on the label. Still, I remain unrepentant.

Branding Distilled Cover Close UpWe hope you’ll use this story and others from our book Branding Distilled: A Guide to Package Design for Craft Spirits to discover the tools and resources you need to successfully operate your own distillery.

 
 

Have Your Own Tale to Share?

Do you have tale from the TTB approval trail to share? Or a label you like to point to to gets your creative juices flowing? Provide your examples in the comments below.

Sub Rosa  Tarragon & Saffron Vodka Bottles
Sub Rosa Saffron and Tarragon Bottles

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