Didn't want to get the board a'flutter with this one. I'm finding several whiskeys being barrelled then going to stainless with oak or other woods and it's not stated on label. In fact, according to the TTB definitions of aging and of whiskey, you could go to barrel for a single month then to stainless for actual flavor pickups from other woods for years.
The TTB whiskey definition of AGE IN OAK BARREL has no minimum times stated/required. A used wine barrel with cherry wood blocks added to the barrel would also pass that test., and it would still be a whiskey. I'm looking to do a rush process in 1-2 years while the 'good' stuff ages out longer. I already know the results are good, just want to know how to sell it to the TTB.
Any ideas or ruling you've seen on this?
Porter, reread the CFR STANDARDS OF IDENTITY from the TTB. There is no reference in the law to "aging" only "storage". It is arguable, though not a tested argument that I know of, the absence of minimum time in oak allows for overnight "storage" in new charred oak. It is no less whiskey in the law if it is new charred oak for an hour or a decade. And the "age statement" can be as simple as "aged fewer than four years".
As for the introduction of other wood or treatment, these must be accounted for in your Statement of Process filed with the COLA application. No reason I can see that it would preclude treatment with other wood of any kind (except those which are poisonous of course)as long as the whiskey meets the Fed definition for the Class/Type and you declare what's in it.
a few comments on what Ralph says...
(1) overnight storage in new charred oak containers makes them no longer new, so since you're paying the money, you might as well use the barrel.
Treatment with wood. The words "colored and flavored with wood (insert chips, slabs, etc., as appropriate)" shall be stated as a part of the class and type designation for whisky and brandy treated, in whole or in part, with wood through percolations, or otherwise, during distillation or storage, other than through contact with the oak container. (from 27cfr5.39)
Ralph is correct - disclosure to the consumer pretty-much covers you, and a formula is probably required.
Couple of points. As stated in the TTB BAM manual for styles, it states the following.
"...in charred new oak containers..." (Notice the term containers.)
From the TTB definitions for the word 'container'....
1. For Wine: Any bottle, barrel, cask, or other closed receptacle, regardless of the size or of the material from which it is made, for the sale of wine at retail.
2. For Distilled Spirits: A receptacle, vessel, or form of bottle, can, package, tank, or pipeline (where specifically included) used or capable of being used to contain, store, transfer, convey, remove, or withdraw spirits and denatured spirits.
Now, notice the definition for container, referring to distilled spirits, doesn't even mention 'barrel' as a container.
So, still worth going down the road to get a ruling with the TTB on 'new charred oak' in stainless steel container as satisfying the requirements of storing/aging.
And label disclosure is not of concern here, not a problem stating it was aged WITH missouri white oak and cherry wood.