Cask ageing of rum - same as adding essences/flavour agents?

[da'rum]

Sounds familiar

[Capn Jimbo]

And here's the real story...



Thanks to JaRiMi who raised this on the last page:

"This is fun...Someone at a different forum told me that "additives are ok, because US law allows 2,5% additives in rum (and quoted Chip Dykstra's website, where the US law was looked at in 2010 I think it was)."

JaRiMi - there was no "study" short of his own "look at" it at bedtime reading over a brimming glass of Diplomatico. And if you read his borrowed material, and unless he deleted it, I posted a reply countering his long, convoluted and weird interpretation.


This is an excellent moment to revisit some old history. Back before the Furry Frozen One invented his own bizarre "methodologollygee" - before gaining experience, and then declaring himself an "reviewer" of rum, then whisky, then gin, then tequila, then wine... whew! ... I engaged with him in a roughly six month long series of many exchanged private emails. My objective:

To educate him and hopefully to gain an advocate for purity and honesty in rum.

I failed. In that exchange he sought my agreement not to discuss these emails, but then had the audacity to publish his completely amateurish laywolf readings of the US regulations - but only after I had provided them in detail to him, specifically and with accepted interpretations.

But as a seller of baseball cards (really) he also fancied himself a legal researcher - sans research of course - on the regulations. His posting of the 2.5% myth is simply the ravings of a Mickey Mantle fan. The truth: the notion that what I called "the additives clause" allows up to 2.5 of additives without labeling is unequivocally false. I'd even spoken with the Department who confirmed that additions of sugar and flavorings (ala Ron Matusalem) are verboten under the regs for "Rum".

You see, the Wolf's favorite rum was Diplomatico Reserva Exclusiva and received one of the highest ratings he's ever awarded. In our emails he completely rejected the idea that this sugar bomb was altered in any way. I dared him to at least publish his opinion, but this too was refused on the basis that if he didn't know "for sure", he demurred from tarring the distiller in any way. The real truth:

I don't think he trusted either moi or his palate; nor did he wish to face the idea that any rums were unlawfully modified. He even rejected Richard Seale's commentary to the contrary, nor even an example of One Barrel - whose website and interviews even admitted the additions to what they labeled as "rum", not "flavoured rum".

At that time he was just another pheromonic member of the "...it's all good" monkey mob. To even question a rum as - horrors - containing unlabeled additives was heresy to a neophyte desperate for acceptance.


I didn't want to do this

Under § 5.22 The standards of identity

1. "Rum" is distilled from the "fermented juice of sugar cane, sugar cane syrup, sugar cane molasses, or other sugar cane by-products... at less than 190° proof... bottled at not less than 80° proof; and... mixtures solely of such distillates.".

2. "Flavored Rum" is merely rum with "added natural flavoring materials, with or without the addition of sugar, and bottled at not less than 60° proof. The name of the predominant flavor shall appear as a part of the designation."

In other words add any flavoring materials, including sugar and it has to - has to! - be labeled "flavored rum" - and must also label the "predominant flavor". Period. No exceptions. The keen minded will not the use of the word "natural", but rest assured this term has no defined legal meaning.

Now the Wolf's copout - of which he was well informed by moi - is another clause which I call the "Additives" clause. The actual name is...


The Alterations Section

§ 5.23(3) Alteration of class and type.(a) Additions.

This is the cave into which the Wolf hides to cover his mistaken impressions. The "Additions" paragraph states:

"The addition of any coloring, flavoring, or blending materials... except as otherwise provided in this section, alters the class and type... and the product shall be appropriately redesignated."

In other words - add flavoring to "rum" and it must be redesignated as "flavored rum". But - but the keen eyed Wolf pounced on the phrase "...except as otherwise provided in the section". Trust me, section 5.23 is a long, long haul with multiple sections and subsections, but allow me to extract the parts behind which Wolfy cowers and whimpers. Here's the key phrases extracted for your reading pleasure:

"There may be added... such harmless coloring, flavoring, or blending materials as are an essential
component part of ("Rum")".

Let's pause here...

The key: The regs clearly define "Rum" and its "essential component parts", namely "cane juice... cane syrup... molasses... and sugar cane byproducts". This might allow added sugar as a byproduct, but only if "flavored rum" were not defined as containing "added flavoring materials, with or without the addition of sugar. In other words, Wolfie is proceeding on the notion that the "flavored rum" definition did not exist. Further subsections of Alteration make a couple more exceptions.


More Exceptions

Subparagraph (2) of Alteration expands things and also allows the "harmless coloring, flavoring, or blending material" but only - sorry Wolfie - but only if these "are customarily employed... in accordance with established trade usage (and) do not total more than 2-1⁄2 percent by volume". Wolf's twisted and self-serving skimming goes something like this "Hey, rum distillers have added all kinds of things over the years, so that is 'customary' and, uh, must be allowed up to uh, 2.5%, right?"

Wrong. Why?

Simple. The Furry One has misdepended on the word "customarily" and ignored the rest of sentence which adds only "in accordance with established trade usage". In fact, he never even discusses this limitation. "Established trade usage" means a practice that is done with such overwhelming regularity by all, that the practice is expected. Further, the usage must be specifc. Believe me, this has been litigated to death, and the body of findings is massive.


Established Trade Usage?

Take Ron Matusalem's prunes. If the addition of prunes was so regular as to be expected from all rums, then this would qualify as established trade usage and could be sold as "Rum". In fact if a supplier of what he called "Rum" did NOT include prune extract, whether specified or not, he could be sued, and he would lose.

Another example:

You are in love with J-Lo and the new Fiat 500's. Lovely, fun little car - you see a special and limited sale, rush off to the dealer and plunk down yer pesos for hot, bright red one for $1000 off, sign the sales agreement, go home and wait for the call. When - Yes!! - you get the call, you excitedly race to the dealership, are handed the keys, go out to the delivery area and there it is! Wow!

But then you see all the wheels are missing? What?! "WFT!!" you scream and tear into the showroom and demand to see the manager. "I'm missing my wheels, they must have been stolen - WTF is wrong with you? How do you expect me to drive it?". "Oh... but we didn't promise you four wheels, now did we? Hey, you got a $1000 discount, didn't you? We'll be happy to sell you some nice new ones for, uh, $1000, how'd that be?"

The truth: selling a car with wheels is done with such widespread regularity that it becomes "established trade usage" and no longer has to be specified. Red? Specify. Leather seats? Specify. Ordinary wheels? Nope, that's expected. Capish? Not the Wolf. But there's more. Although Wolfie loves to quote selected phrases from all of the above he never quotes the final subparagraph of the Additives section, namely...


Exceptions to the Exceptions: The Final Exception!

(c) Exceptions. (1) This section shall not be construed as in any manner modifying the standards of identity for... flavored rum, flavored vodka, and flavored whisky"

You see, the Additives clause is really a list of authorized exceptions as covered, and like so many other regulations and clause has its own Exceptions clause, in this case simply that nothing in the Additives section overrules the more basic and primary definitions of the standards of identity. First you create a standard of identity, here for "Rum" and "Flavored Rum" and all the other common spirits. Then - certain additives (exceptions) are authorized under but only under very specific circumstances (like established trade usage) - but - not in any way overruling the primary definitions.

In this case "flavored rum" is defined very simply as the addition of any "flavoring... with or without sugar". That's pretty straight forward. The Wolf wants all to believe that a "Rum" can be altered up to 2-1/2% with any flavoring or additive - established trade usage be damned - as if "flavored rum" was never defined. Even the Alteration section which he credits makes clear that such alterations may not "in any way modify the standards of identity for... flavored rum".

BTW, 2-1/2% of any material is a huge amount, especially for artificial flavorings. Add that much vanilla flavoring and you'd be spitting up. The honest truth: the only difference between labeled "Flavored rums" and Wolfie's unlabeld altered "Rum" is... the label.


Way Flat Ass Bottom Line

Now you know why I really, really, really didn't want to get into this. It gets even worse since I contacted and spoke with the Department who were quite clear that such additions were not permitted to be labeled "rum". Furthermore, the real meat and potatoes are not really in the regulations but actually in the literal thousands upon thousands of findings, reviews and communiques made by the Department over the years.

This gentleman's study is anything but convincing. You may return to your lawbooks...




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[sailor22]

Even in the Bourbon and Whisky industry the regulators rely almost completely on self regulation by producers. They don't look at a label and consider it's accuracy or its compliance by their own initiative. Which is to say they aren't investigative in nature.

BUT if a competitor OR KNOWLEDGABLE CONSUMER gets in touch with them and specifically points out labeling that is counter to regulations or standards they will pursue the question with the producer. A pretty straight forward process for spirits manufactured in the USA and producers typically voluntarily comply with a "sorry about that, my mistake" shuffle. But perhaps it's more complicated when it involves imported juice.

Given that everything is clear when it comes from the still head any color could be considered "added" in one sense. However "barrel aged" brings with it a set of flavors and coloring that is understood and accepted as part of the traditional product. I expect the difficulty is that in some countries the traditional Rum product contains additives and flavorings.

I have noticed that most Rum producers come off the still at very high proofs, probably for financial reasons. The higher the proof the less the juice carries any flavor of the original mash (it's closer it is to vodka). When the original product is nearly flavorless it is tempting to sex it up with added flavoring ingredients.

I am curious what both a molasses based and cane based product would taste like at something in the range of 90 or 100 proof off the still, much more flavorful I would think and more differentiated.

[Capn Jimbo]

Great stuff...


I really don't know of any commercial rums produced at 45-50%, but there are some in the 70+ range. I'd also think about a very fine rum - Smith & Cross, delivered at 58% (but no doubt distilled to a higher percentage).

From their material:

Through the 19th century and into the earlier 20th century, Jamaica Rum was revered for its deep full flavors and pleasing aromas. In this era, rum fell into three general classes, Local Trade Quality, Export Trade Quality (mainly an ester-intensive "High Continental" style for the German market), and Home Trade Quality for UK (and US) consumption.

In the mid 20th century appeared the more familiar "Common Clean" light and/or sweeter styles on offer today, made with the column-still product introduced in the late 1950s. The heavier bodied Wedderburn and medium bodied Plummer styles were made with a combination of the molasses, skimmings, cane juice, and syrup bottoms from sugar production, and the dunder of the previous rum production.

A Jamaica tradition has been the use of wild yeasts indigenous to the region in the fermentation process, which is arguably a major contributor to the special body and flavor. The end result is a rum of tremendous and local character.

And from another post here:

Dunder produced rums were such a part of Jamaican rums that even today rums are classified as to their ester content: Common Cleans (80-150 esters, light and floral), Plummers (150-200 esters, light and fruity), Wedderburns (200+, deep fruity, heavy bodied and pungent) and last Continental Flavored/High Ester (50-1700 esters, by far the most pungent, acetones). Where a Plummer might be fermented for 2 days, a Continental might take 5-10 days, or more!

The Common Clean, light ester rums are really quite modern (1950's) and are produced using continous column distillation. Most Jamaican rums are blends relying on the Plummer/Wedderburn categories for their flavor components.

What is relevant here is that S&C probably averages at least 200+ different esters, compared to 35 to 50 esters in what now passes for most rums. That is about as flavorful as most of us are likely to experience. Interestingly, S&C is aged only from 1 to 3 years, as they wish to avoid oak effect that would overpower or reduce its flavors in the mid-term.