The labeling FAQ discussed here on Monday contains nothing new concerning the rules as written, but it does represent major changes in how TTB has been enforcing those rules. Several producers have told me that TTB advised them that only straight whiskey needed an age statement if less than four years old, and many products have been mislabeled as a result of that advice.
Here is the easiest way to understand the rule. If the label says 'whiskey' on it, and the product contains no neutral spirit (i.e., vodka, as in Seagram's 7 and similar products), and it is less than four years old, it needs an accurate and specific age statement, which is the age of the youngest whiskey in the bottle.
That's pretty much it. No exceptions. An age statement is required if the product meets all three of the following.
- 'Whiskey' on label.
- No vodka in the product.
- A whiskey in the product that is less than four years old.
TTB has, of course, not acknowledged that it has regularly mis-applied its own rules. Let's just hope they get it right going forward.