Problem with EU's Definition of Rum

Hello guys!

I have had a visit from The Swedish National Food Administration. The lawyers says that my rum is not rum because of my use of raw sugar in combination of molasses. What do you say about that?

«1

Comments

  • When you say raw sugar,,, do you mean that it has been processed by centrifuge?

    StillDragon North America - Your StillDragon® Distributor for North America

  • Will they allow for evaporated cane juice?

    No sucrose extraction technique. Only water extracted from cane juice.

    StillDragon North America - Your StillDragon® Distributor for North America

  • Like Panela? I don't think so. The lawyers are reading the law very literally. This is the law text:

    Rum is:

    (i)

    a spirit drink produced exclusively by alcoholic fermentation and distillation, either from molasses or syrup produced in the manufacture of cane sugar or from sugar-cane juice itself and distilled at less than 96 % vol. so that the distillate has the discernible specific organoleptic characteristics of rum, or

    (ii)

    a spirit drink produced exclusively by alcoholic fermentation and distillation of sugar-cane juice which has the aromatic characteristics specific to rum and a volatile substances content equal to or exceeding 225 grams per hectolitre of 100 % vol. alcohol. This spirit may be placed on the market with the word ‘agricultural’ qualifying the sales denomination ‘rum’ accompanied by any of the geographical indications of the French Overseas Departments and the Autonomous Region of Madeira as registered in Annex III.

    (b)

    The minimum alcoholic strength by volume of rum shall be 37,5 %.

    (c)

    No addition of alcohol as defined in Annex I(5), diluted or not, shall take place.

    (d)

    Rum shall not be flavoured.

    (e)

    Rum may only contain added caramel as a means to adapt colour.

    (f)

    The word ‘traditionnel’ may supplement any of the geographical indications mentioned in category 1 of Annex III where the rum is produced by distillation at less than 90 % vol., after alcoholic fermentation of alcohol-producing materials originating exclusively in the place of production considered. This rum must have a volatile substances content equal to or exceeding 225 grams per hectolitre of 100 % vol. alcohol and must not be sweetened. The use of the word ‘traditionnel’ does not prevent the use of the terms ‘from sugar production’ or ‘agricultural’ which may be added to the sales denomination ‘rum’ and to geographical indications.

    This provision shall not affect the use of the word ‘traditionnel’ for all products not covered by this provision, according to their own specific criteria.

  • I checked with a Dutch rum expert (same EU-wide law text), he agreed that the text should be interpreted literally. But only if the authorities check ;)

  • Thanks @squeakyclean. I can not fight the authorities so I will do an all molasses recipe in the future. Unfortunately I have a lot of raw brown sugar waiting in the storage now so I have to find another use for it :)

  • Swedish chef's Moonshine?

  • Yeah! Something like that! :))

  • Swedish Lightning?

  • One word on the label: Måne ...with a picture of a full moon reflected on water...or use your imagination. Whatever the laws permit...work within those parameters. Unless you want to branch out into making candy with all that sugar.

  • edited March 10

    If you are reading it literally as they suggest then the term 'sugar-cane juice' implies sugar or cane juice to me rather than sugarcane juice only.

    It's just that sugarcane is a word and sugar-cane is not.

    Sugarcane juice @ Wikipedia

    StillDragon Australia & New Zealand - Your StillDragon® Distributor for Australia & New Zealand

  • Spoken like a lawyer

  • @lsydd: I used to make candy about 8 years back. Chocolate pralines :\"> Måne? Do you speak Swedish?

    @Punkin: Cane juice has always meant the same as sugarcane juice for me. But English is only my second language and the ones writing the law is certainly from Brussels and speak Deutch. :-j But I read the Wikipedia now and see that cane juice can be interpreted as sugar. So I am right in a way?

  • Well i wouldn't rely on a wiki entry when arguing with lawyers, but i'm sure you can find some credible references. I do think you've been left an opening with the hyphenated wording is all.

    StillDragon Australia & New Zealand - Your StillDragon® Distributor for Australia & New Zealand

  • We have Inländer Rum in Austria, made of sugar. I would guess, that they use the name lawful.

    StillDragon Europe - Your StillDragon® Distributor for Europe & the surrounding area

  • Interesting @Sunshine. I am trying to find what it is made of. It seems like the recipe is secret, but I have always heard that it is made of beets. If so, with the EU and the US standard identities, it is not rum. But it sells as rum in Sweden though.

    I have made some calculation this weekend. I found that if I adjust my recipe to an all molasses wash, with the same sugar rate as with molasses and raw brown sugar, the cost will be the same. I think it may be a win situation anyway. Better rum. Although I think the product so far is very good. The still is making a good job :)

    1. Dried sugar cane juice, or sugar cane juice in crystal form are completely arguable as sugar cane juice... how is what you have not describable as those?
    2. If you turned the brown sugar to liquid, you could call it sugar cane syrup, and that is stated as acceptable...
    3. if you decided to buy sugar cane juice fresh and YOU crystalized/centrifucged/whatever, it would still be made from sugar can juice... correct?
    4. if you had a 3rd party turn it to liquid and label it 'sugar cane syrup - made from dried, reconstituted sugar cane juice', they would not be dishonest, and you would be legal...
    1. I have raw brown sugar from sugarcanes. I think the problem lays in the fact that this sugar is more refined than just crystallization of the syrup. It is centrifuged.
    2. That I can't do. The NFA would ask me about the distributor and a product sheet for the juice.
    3. I know that, but the lawyers at NFA will not listen to my arguments. They have no clue about the processes in the sugar production.
    4. Will be more expensive then if I do as they are saying.
    1. centrifuged is not a chemically changing process...
    2. that was an explanation of 'adding water', if 'adding water' changes the composition, then every rum maker that 'adds water' to molasses before fermenting is 'changing the composition'...
    3. hire a lawyer...
    4. more expensive than throwing away what you have now ??? you can buy molasses, but it sounds like you were asking what to do with product you have now..

    Heck, for current brown sugar, you could buy some molasses and dump the brown sugar in it... how would anyone know?

  • By an accountant asking where all those bags of brown sugar are going?

    I'm not a lawyer either, but I agree with punkin and there's got to be someone who has successfully made this argument in court already.

  • @CothermanDistilling @RobertS : most tax authorities require distillers not only to keep a detailed administration of their finances and any kind of ethanol, but also fermentable products (grain, sugar) and to a lesser extend even bottles, caps and labels.

  • I am a professional distiller and know this... we have to keep detailed daily records and be able to track all ingredients from a single case back to the origin of each ingredient too... none of these things keep you from legally working within the system to get your raw material approved... our suggestions are things to try short of throwing the sugar out or making 'not rum'...

    Might be a good idea to get the formula approved before buying the raw ingredients...

  • @MotherOfDragon : do you actually need to get a formula approved? Or is it just that the authorities might check your used ingredients and procedures for the product type on the label? Here in NL we are of course bound by the European rules for specific well known drinks, but if I put "distilled spirit" (gedistilleerde drank in Dutch) on the label almost anything goes and I don't have to get a formula approved like in the USA. I can actually sell my jenever as dry gin as the product fits both (overlapping) rulesets.

  • @squeakyclean : Yes, I do need to get a formula approved for each product type. I live in the most bureaucratic country in the world. I want it to be rum so I must change my recipe. I am waiting for them to get back to me this week. And I am gathering some arguments right now.

    @CothermanDistilling said: Might be a good idea to get the formula approved before buying the raw ingredients...

    I never thought that raw brown sugar from canes should not be approved. And I do use molasses as well. My question might have been unclear. I wanted to know if I was wrong about the raw sugar because it seems that a lot of distillers uses it if reading at ADI forums and other places.

    The good thing is that I don't have to throw away anything.

    It is not a big deal to change my recipe to an all molasses recipe. I just get frustrated about the lawyers inability to read and learn about things. Rum processes, sugar production and so on.

  • I think 'raw sugar' and even 'raw brown sugar' are too generic to make any kind of judgement on...

    To me, 'panela' is the new standard for the term 'raw brown sugar'... and that should absolutely be accepted to make rum from by anyone's definition...

  • Are you buying from a distributor with sales representatives? They might be able to help out with proving you meet the definition, it being in their interest for you to keep buying that sugar from them.

  • @CothermanDistilling said: I think 'raw sugar' and even 'raw brown sugar' are too generic to make any kind of judgement on...

    To me, 'panela' is the new standard for the term 'raw brown sugar'... and that should absolutely be accepted to make rum from by anyone's definition...

    Agree

    A strike, B strike , and C strike should be the terms used for extracted sucrose.

    StillDragon North America - Your StillDragon® Distributor for North America

  • The official EU definition for Rum is a distilled beverage from fermetation of 96% vol of melasses or sirop originating of the production of cane sugar.

    Hence, if you use pure organic certified cane suger with documents of origin and you use that to make your own specific cane sugar sirop for fermentation you are making rum according the specific regulations of the EU.

    It is just how your interpetation is of the regulations and how you describe your own internal production guidelines.

    The price of EKO certified organic raw cane sugar is more expensive than regular commercial sugar. But we also believe that the end product is also much higher in quality using this more expensive ingredient.

  • Hi @MokumMoonshine! I use EKO certified organic raw cane sugar. Very nice and high quality from Paraguay. The sugar company is the largest in our Nordic countries.

    @MokumMoonshine said: Hence, if you use pure organic certified cane suger with documents of origin and you use that to make your own specific cane sugar sirop for fermentation you are making rum according the specific regulations of the EU.

    But this is the problem. The lawyers do not accept this sugar even if I tell them that I can make it to be syrup again :-j

  • Anyway. I think it is time to end the discussion. I will just fall in the line and do what I have been told. But my inner pirate is screaming! :ar!

Sign In or Register to comment.