Brandywine Branch Distillers and the TTB Work Together After Label Disapproval

Scott and Don Avellino’s Brandywine Branch Distillers, distillers of award-winning craft spirits Revivalist Botanical Gin and Resurgent Whiskey, have been looking to expand production by creating a new and innovative gin. And while they have found a style that they have fallen head-over-heels for, a very interesting and unforeseen hiccup recently interrupted their plans for rollout.

Brandywine Branch tapped Sandstrom Partners, a world-renowned Oregon-based branding and design firm, to create the new eye-catching and innovative packaging for their new product. Sandstrom Partners have developed packaging for the likes of Aviation Gin, St. Germain, Miller/Coors, and Mi Campo Tequila. On July 6th, 2022, Brandywine Branch filed the paperwork for their new Revivalist Garden Gin with the U.S. Alcohol and Tobacco Tax and Trade Bureau (TTB). Three weeks later, on July 27th, Brandywine Branch Distilling’s certificate of label approval/exemption (COLA) was in hand. However, on November 4th, the Avellinos received an email from the TTB reversing their decision to approve the label.

The email, in short, stated that the submission was not in compliance. The TTB’s concern was that the use of the stylized “R” on the packaging mimics the abbreviation “Rx,” which is prominently displayed on the front label. “The language implies that the gin has medicinal qualities. Upon further review, TTB determined that the COLA was approved in error…” according to the email. The email went on to list the reasons for the approval error, stating that the label “implies that the product can be used as a medical prescription, and that the consumption of this gin will positively affect the health of the person who drinks it.” The TTB then went on to explain that the stylized “Rx” must be removed from the top center of the label.

Don Avellino immediately contacted the TTB for further explanation on November 7th and was told that the agency was “very sorry, and that they approved the label by mistake.” Avellino noted that the TTB was very helpful in providing advice to bring the label into compliance, and that the TTB agreed to work with Brandywine Branch to mitigate any purchases of the already approved label and discussed a path forward that would not jeopardize the company in any way. Brandywine Branch and Sandstrom quickly made final adjustments that alleviated the TTB health concern, and submitted the revised label on November 10th, which gained approval on November 14th.

“Although the reversal of the approval label was unfortunate, I was very pleased with how the TTB handled the situation, and how eager they were to help us find a solution,” said Don Avellino. “The TTB has proven to be a fantastic partner, and we’re excited to finally launch the product shortly.”

The Revivalist Garden Gin is an all-natural, next generation, botanical-forward gin infused with sustainably-produced ethnobotanicals with zero additives, preservatives, other natural flavors, made with botanicals that are curated from around the globe and in Brandywine Branch Distilling’s backyard. As part of the Avellino’s focus on taking this produce from regional distribution to additional U.S. and international markets, they have added two key personnel to their executive team: industry veteran Chris Papariello as President, and Steve Luttmann, who brings 30 years of branding experience in senior executive roles, joined the Board of Directors.

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