Revise TTB Regulations governing "Mead" beverages

From Ken Schramm:

"I am writing to ask if some attention can be given to a situation with the TTB that is affecting the burgeoning mead industry. Mead is a small but growing part of the beverage alcohol trade. Having reviewed the TTB’s web site, I have not been able to find mead-specific rules or documented interpretations that address the nature of the mead industry.

The areas that create challenges are recipe formulation and label approval. The Formulas tab of the TTB Online “Formulas Online” submission tool requires that all fermentable ingredients be listed as percentages by volume. For every beverage except some distilled products, water is, in fact, the largest volumetric ingredient. For meads made with fruit, however, the largest contributor of extract (honey), and the largest contributor of volume (fruit or fruit juice) are going to be different.

Throughout the mead world, if the majority contributor of extract to a fermented beverage is honey, the beverage is mead. This has been the case across many different cultures and for many centuries. Irrespective of adjuncts such as fruit or spices that may be part of the recipe formulation, if more than 50% of the extract in the must is contributed by honey, the beverage is, above all else, mead. For purposes of analysis, the formula would be:

G/B ÷ (HV/B) = N

Where:

G = Original Gravity of entire batch in Brix
B = Volume of batch
H = Gravity of honey in Brix (Average = 82.8 Brix)
V = Volume of honey
N = Percentage of extract from sources other than honey

To be mead, the quotient N must be less than .49. I am asking that the TTB permit any beverage that comports to this formula to be labeled as “Mead.” Sadly, and quite ironically, the TTB is refusing to allow beverages that comply with this definition to be labeled as mead, saying that such labeling would be misleading. In truth, to allow a beverage which has more than 50% of its extract from honey, and more than 50% of its alcohol produced from the fermentation of honey to not be called “mead” would be misleading.

It would also be valuable for mead producers to be able to add descriptors “Fruit Mead” or “Spiced Mead” to mead labels without fear of rejection, in much the same way “Ice wine” or “late harvest wine” are used to describe some grape wines.

Implementation of this standard would help in two ways. First, the Bureau would be applying the same nomenclature to label and recipe formulation standards that mead makers do. Secondly, it would permit labeling which would help consumers grasp and understand mead as a beverage. For mead makers and mead-aware consumers, fruit meads (melomels, cysers or pyments) or spiced meads (metheglins) are meads, in the same sense that Port, Sherry and Sauternes are styles of wine, but still wine.

This change would also create a fairer, more objective standard. Mead makers who use fruit concentrates currently get an unfair advantage. If you use real fruit, the larger percentage of fruit (volumetrically) may prevent you from labeling the product as mead. Use concentrate - smaller quantities of a lower quality ingredient than those who use real fruit - and honey can appear to contribute quantitatively the greatest volumetric share of the must, and enable the product to be labeled “Mead.” In reality the fruit juice, which is being reconstituted with the addition of water, is contributing the greatest volume in the product. This interpretation tilts the recipe formulation and labeling decision-making process away from conscientious, quality-minded mead makers, and away from the interests of the consumer, both outcomes I do not think the TTB would consider its goals.

I am making this plea from two separate standpoints. As a fledgling commercial mead maker, I am seeking to create a playing field that will allow me to do business effectively, compete, prosper and create jobs. I am also a serious mead enthusiast, the founder of the Mazer Cup Mead Competition, the largest mead competition in the world, and the author of “The Compleat Meadmaker”(©2003, Brewers Publications, Boulder, CO), the best selling book on mead making (perhaps ever). It might be immodest, but it is not inaccurate to say that I may be the most widely read authority on mead alive. For more than 25 years I have been studying mead, making mead, writing and speaking around North America on mead. I am deeply committed to the growth of this industry, which supports mead makers, mead lovers, beekeepers, fruit, spice and beverage production equipment manufacturers and wholesalers. It is my intent to make the best meads I possibly can, and meads they are, by the common interpretation of those most familiar with the beverage. It is my hope that the TTB will consider using the same definitions of the beverage that those who know and make it use to define it. These current interpretations by the TTB labeling staff are causing harm to this young and growing industry."