Thursday, April 26, 2018

Wild Turkey Takes a Broad Swipe at Traditional Age Statements

Labels for beverage alcohol products must be submitted in advance to the Alcohol Tax and Trade Bureau of the United States Treasury Department (TTB). The image above is of a recently-approved Wild Turkey back label.

Labeling watchdog Wade Woodard discovered it and did an awesome detective job, getting both TTB and Wild Turkey parent Campari on the record about the label's questionable statement about ages. You really should read his account, which can be found here on his 'Tater-Talk' blog.

The gist: Since this whiskey is more than four years old, an age statement is not required. If, however, a statement about ages is made it must be truthful and in the standard form, which is "this whiskey is ____ years old," or one of several acceptable variations of that sentence. If the product contains whiskeys of different ages (as most do), its official age is the youngest liquid in the bottle, except that the age of each component whiskey can be given if the percentage of each is also stated.

Wild Turkey's wording, "...this iconic bourbon is perfectly aged for up to six to eight years...," would seem to be non-compliant, but Wild Turkey found a loophole. The rules provide that labels "not required to bear a statement of age ... may contain general inconspicuous age, maturity or similar representations without the label bearing an age statement.� By that analysis, Wild Turkey's statement about age isn't an age statement, it is an 'inconspicuous representation' about age.

When brands have made 'inconspicuous representations' about age in the past, it has been with phrases like 'fully matured' or 'extra aged.' They have eschewed numbers. Sneaking numbers in is the new trick Wild Turkey has pulled off.

Although all this may be legal, it rubs Woodard the wrong way. Me too. It tells you nothing. It is as if they put "this whiskey might be six to eight years old" on the label. They might as well say, "hey, it's possible some 8-year-old whiskey found its way into this bottle, but who the hell knows?" All you really know is what you already knew from the absence of an age statement, which is that the whiskey is least four years old. But many consumers will read it as the whiskey is between six and eight years old, even though it actually says no such thing. It is much like a trick Wild Turkey pulled about 25 years ago when it took the words '8 Years Old' off the label and replaced them with 'No 8 Brand.' Many others have used the same trick when they dropped their age statements.

One can also dispute the new label's claim that Wild Turkey bourbon has a 'high rye content.' The Wild Turkey bourbon mash bill is 75 percent corn, 13 percent rye and 12 percent barley malt. That is more rye than Jack Daniel's (8%) but less than Jim Beam (15%) and way less than Old Grand-Dad and Bulleit (each about 30%).

In general, it is bad practice for brands to trick or otherwise mislead consumers. It undermines trust. The terminology and rules are already confusing enough for consumers without muddying the water and making things worse. Wild Turkey has always been well-regarded among whiskey fans and Wild Turkey master distillers Jimmy Russell and Eddie Russell command enormous respect. It is unfortunate that the brand's marketers have decided to disrespect their consumers in this way.

Since actor Matthew McConaughey is now Wild Turkey's 'Creative Director,' this probably is all his fault.

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