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Cider Digest #1365
Subject: Cider Digest #1365, 31 January 2007
From: cider-request@talisman.com
Cider Digest #1365 31 January 2007
Forum for Discussion of Cider Issues
Dick Dunn, Digest Janitor
Contents:
RE: COLA ("Richard Anderson")
cider labeling issues ("Dan Wilson")
2007 Upper Mississippi Mash Out Results ()
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Subject: RE: COLA
From: "Richard Anderson" <baylonanderson@rockisland.com>
Date: Thu, 25 Jan 2007 17:40:34 -0800
I prefix this by stating that I am not an attorney, however my sense is that
if the product you sell is cider under 7% and you label accordingly,
complete with the contents on the label as required by the FDA no COLA would
be required. However if it is sold as wine, then the label is approved by
TTB and I assume TTB would require a COLA for some specialty ciders
including those which are back sweetened. I think some ciders makers labeled
their cider as wine and pay wine taxes. I would assume one reason to do this
is to package the cider more like wine and eliminate the need for a contents
box. This is a murky area, perhaps there are some people who have a better
understanding of the regulations on the Digest and will share with us.
------------------------------
Subject: cider labeling issues
From: "Dan Wilson" <slyboro@capital.net>
Date: Thu, 25 Jan 2007 21:36:43 -0500
Hi to all. Long time Digest reader, first time caller...
We are on the verge of opening our new cider house/farm winery, focusing
on ciders, in upstate New York. This is an outgrowth of our current
apple orchard and fresh cider business. Many years in the planning,
we're just now to the point of bottling our first thousand cases (we're
starting with one still cider, two sparklers and an ice cider made from
frozen cider, not frozen apples).
As any one of you who are further along in this process will affirm, the
regulatory hoops we need to jump through at each point along the way to
producing and then sell this stuff are sometimes only made tolerable
with a tall glass of our final product to blunt the frustrations
involved. The bigger the frustration, the earlier in the day we conduct
our "sampling sessions". All in the name of quality control, of course.
I'm keeping a chart.
Our current issue is one I'd like a bit of feedback on from other
vantage points, both geographically and in terms of business
development. LABELS. Here's my understanding of the federal and state
laws... The TTB defines "hard cider" as having an alcohol content of
less than 7% and is therefore not regulated by TTB, but FDA. New York
also holds to this definition and further requires a sample of finished
product to analyze before their label approval and brand registration.
However, state Liquor Authority laws clearly state that if a NY winery
obtains a Certification of Label Approval (COLA) from TTB for a wine
(anything over 7%), that no state brand registration or label approval
is necessary; they will just rubber stamp the approval.
Further, the federal regulations (specifically in rule 27 CFR Part 4.21
(e) (5)) state that a product made exclusively from apples, using normal
wine-making techniques, can be classified as "Cider". This rule does
not include any alcohol content language. Therefore, it seems we can
make a lower alcohol product and call it "hard cider" or a higher
alcohol product and call it "cider" and never the twain shall meet.
This not only seems a bit backward, but misguided and arbitrary. But
fine, I'm perfectly happy to call our stuff "Cider", and have designed
labels accordingly. Just please don't make me call my higher alcohol
cider Apple Wine.
We've already gotten three labels through the COLA process, refering
each time to the above referenced rule (seems they sometimes need a
reminder about their own definitions), calling each one a "Cider". Our
ciders, made from a combination of dessert and cider varieties, range
from 8 to 9%, and our "ice cider" is 11% with no fortification up front
(with sugar) or at the end (with supplemental alcohol). That's just the
way they turned out.
Here's my current dilemma- I can't find language in our state law that
parallels the more permissive classification of "cider" at the federal
level, and might get hung up by the state on a restriction that permits
only lower alcohol product to use the "cider" designation. I've followed
all the guidance from the state and TTB to this point and don't wish to
"push the envelope" on this, but I really want to call our ciders,
"Cider". Any thoughts or related experiences would be greatly
appreciated ( I just hope they're not utter horror stories!)
Thanks for the input.
Dan Wilson
Slyboro Cider House
slyboro@capital.net
------------------------------
Subject: 2007 Upper Mississippi Mash Out Results
From: <Paul_Dienhart@cargill.com>
Date: Tue, 30 Jan 2007 09:18:48 -0600
Results, recipes and photos from the Upper Mississippi Mash Out are
posted at www.mnbrewers.com/mashout/ <http://www.mnbrewers.com/mashout/>
Photos can be found at the bottom of the recipes, and more will be going
up today.
The Mash Out awarded 105 medals, including Best of Show carved wooden
chalices for beer, mead and cider. Every winner received a prize.
Score sheets were in the mail within three days. The Best of Show
winning beer was a sour beer: a Berliner weisse by Kris England.
This year, more than 120 volunteers from eight states and Canada
answered the call to help run what has become the third largest beer
competition in the country. Not bad for a six-year-old contest. To all
those volunteers, a huge THANK YOU! It was a great collaboration
between the St. Paul Homebrewers and the Minnesota Home Brewers
Association.
Held last Friday and Saturday in St. Paul, Minnesota, the Mash Out
experienced a 68 percent increase in entries over 2006. The 266 brewers
who entered the contest submitted 918 entries. They represented 66
homebrew clubs and came from 33 states. Clearly, the rest of the nation
has discovered the Mash Out - 525 entries were from outside Minnesota.
There were gold medal winners from both coasts, and Bob Boufford has the
distinction of traveling the farthest: 1,303 miles from Edmonton,
Alberta. We also had the honor of having Gordon Strong, Grandmaster III
judge and BJCP director, contribute to Best of Show judging as well
being head judge of numerous flights.
A special acknowledgement to organizer Al Boyce. Numerous people
stopped by the office to say it was the smoothest, best-run contest they
had ever attended. A lot of dedicated volunteers were behind that, but
it started with Al.
Be sure to be part of it next January!
Paul Dienhart
Mash Out Publicity Chair
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End of Cider Digest #1365
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