Lesson V - Labels and their contents
(To read the previous lessons, please visit the Got Rum? Archives page)
In last month’s lesson, we explored some of the consequences associated with the different types or styles of rum that we could choose to put inside our bottles. In this lesson we’ll explore the information that typically appears on the bottle labels.
Why are labels needed in the first place? This may seem to be a silly question, but we need labels because products (rums, in this case) can’t tell consumers or authority figures everything they need to know about their composition. But labels also provide a canvas where brand owners may include information related to the image or branding of each particular product.
In other words, labels exist primarily to meet communication requirements and secondarily to help promote the products themselves. Once the legal requirements have been fulfilled, the label may contain any additional information, as long as it does not contradict any of the legal requirements. So let’s take a closer look at some of the most relevant requirements.
Legal Requirements
Each country will have its own legal requirements. In the USA, these requirements are outlined in the “Beverage Alcohol Manual,” and every company wishing to sell its rums in the USA should download and study this free document. The sub-title of the manual is “Basic Mandatory Labeling Information For Distilled Spirits” and, as the name implies, is devoted entirely to the subject at hand. Chapter 1 is devoted to the type of mandatory label information, which includes, among other items:
Brand Name
• Class and Type Designation
• Alcohol Content
• Presence of Coloring Materials
Chapters 2 through 9 deal with the specific details of how all the items enumerated in Chapter 1 are to be disclosed or even if such disclosure is waived for certain products.
Rum, for example, is described by the manual as
“Spirits distilled from the fermented juice of sugar cane, sugar cane syrup, sugar cane molasses or other sugar cane byproducts at less than 95% alcohol by volume (190 proof ) having the taste, aroma and characteristics generally attributed to rum and bottled at not less than 40% alcohol by volume (80 proof )”.
The manual also defines that rum may include up to 2.5% of “Harmless Coloring, Flavoring and/or Blending Materials” with NO label disclosure being required. The Manual includes a list of approved coloring materials, and defines two approved Blending Materials: wine and sugar. Everybody understands what sugar is, but wine? Well, a lot of blending products have earned the definition of “wine” so their use can be covered by this clause. Whisky, for example, can have up to 2.5% of “Blending Sherry” (considered a wine) and not have to declare it on the label.
The implications from the above statements are wide and far reaching. On one hand, we should understand that all rums would need to have at least 40% (80-Proof ) of alcohol in them, yet there are many flavored rums (Coconut, Lime, Orange, etc.) with concentration below 40%.
On the other hand, we are being told that, as long as the ingredient we are trying to use has been determined to be “Harmless”, that we can use up to 2.5% by volume and we do NOT have to declare it on the label...
There are other legal requirements, such as standard of fill (1 liter, 750ml, etc.) and who the importer, bottler or producer is, etc. But all these are very self-explanatory. So how can a rum bottled at less than 40% be called a rum on the label?
The answer is, that just seeing the word “RUM ” on a label does not guarantee that the product is a Rum!
Let me elaborate: a product may have the word “Rum” on the label, if the brand owner claims that it is part of the Brand Name (or “fanciful name”), such as in “Coconut Rum”. The reality is that the product may have a Class and Type Designation of “Distilled Spirits Specialty” (instead of “Rum”), which may appear somewhere on the back label or in a less prominent part of the front label. While this is clearly misleading, the practice has not been banned by the authorities, who are happy to collect taxes on the alcohol being sold.
Aging: according to the Beverage Alcohol Manual (Chapter 8), rum is allowed to have either a Specific Statement of Age or a Miscellaneous Age Reference. The former is self-explanatory, but the latter? This is the wording from the manual:
“The miscellaneous age statement is allowed, BUT a specific statement of age must appear as conspicuously and on the same label as the miscellaneous age reference UNLESS the rum is not less than 4 years old and the miscellaneous georeference is general in nature and inconspicuous (e.g., contained in back label text) on the label.”
What about geographical origins? For now, in the USA, the authorities are not regulating the mention of geographical origins. It is permit ted, for example, to say “Jamaican Style Rum” without having the rum produced, aged or bottled in Jamaica. Some countries, however, are star ting to take a firmer stance on the topic, allowing the reference only if the production is tied to the region or country being mentioned.
What about sugar, calories and other nutritional information?
The laws are changing; some people think for the better, others think for the worse. If you are interested in learning more about it, download the June 2015 issue of “Got Rum?” and read the Letter to the Alcohol Beverage Industry (pg. 14), by Dr. Gary Spedding. Some of the tests being required are cost prohibitive for small producers and, in some cases, the procedures and/or methodologies are not rooted in science.
So what should you do, as far as disclosing information on the label?
You should make sure the label meets all the legal requirements of the country where you plan to commercialize it. We recommend hiring a consultant or working with someone who has successfully produced and delivered rum to your target country. Other than that, please be honest and don’t claim anything on the label that cannot be verified by someone visiting the distillery that is sourcing your rum. Don’t claim, for example, that the rum is aged in Sherry casks if there are no Sherry casks at the aging warehouse or if their number is insufficient to age the amount of rum claiming to be finished in them.
Next month we’ll talk about the actual production (bottling) of a private label, shipping logistics, customs and more.
See you then!
Luis Ayala
Rum Consultant