One of the things that they do is classify what your spirit is. They determine whether what you've made is a whiskey, a flavored vodka, bitters, or what have you. You have to meet certain legal qualifications for all of these categories and you'd be surprised how lenient they can be. You can put new make corn whiskey, distilled to no higher than 160 proof, into a new charred oak barrel at no higher than 125 proof for 1 second...and it would be called a bourbon. "Bourbon" doesn't have a mandatory time-in-barrel. "Straight bourbon" does; it's 2 years.
But there's always been one thing that's bothered me: should sugar jack be classified as a rum? For those of you that don't know what a sugar jack is, I turn to one of the two foremost experts on all things moonshine, Matthew Rowley. In his post "A Writer's Guide to Moonshine, Part 1", he goes on to say this:
"In the mythological mountain South, that pure old mountain dew was corn whiskey. But even in 1974, actual journalist Joe Dabney realized that style of moonshine was on the wane, replaced by modern sugar washes that distillers took up in widespread corner-cutting in the 1920’s. In Mountain Spirits, he wrote “The truth is that compared to equivalent figures from five, ten, and twenty years ago, the ‘corn likker’ craft is dying fast.” No, what was around for most of the last 90 years was not corn whiskey at all, but spirits made from table sugar, made fast to be sold fast. The old corn whiskey of our parents’ and grandparents’ eras was rarely corn and rarely whiskey. But it sure was moonshine."
A sugar wash is literally described by its title: a mixture of table sugar and water, fortified with yeast nutrients, that is fermented and distilled. There are a few places these days creating a sugar wash moonshine (the one I'm thinking of is the new Dutch's Spirits which makes a Sugar Wash Moonshine out of Demerara sugar. But one thing that's irked me is, if you were to submit it to the TTB...would you have to call it a rum?
Personally, I feel that a sugar jack shouldn't be classified as a rum even though its fermentation base is sugar, like all rums. But here's why. Rum itself is mainly made of byproducts of the sugar manufacturing process. Your standard molasses based rums, regardless of molasses grading, are manufactured using a byproduct of the sugar rectification process. Even rhum agricole (which is made using cane juice), I feel, is made with a byproduct as there is little commercial viability for fresh cane juice. You can't really export cane juice without heavy processing. Most rhum agricole producers are within an hour or two of a sugar cane pressing site. The reason for this is the biological instability of cane juice. Molasses is hard to inoculate in its uncut form due to the high sugar content. Any bacteria or yeasts that are added to pure molasses rarely survive due to what's known as osmotic pressure. If I can hearken back to basic chemistry here, you may remember that things of high concentration flow to areas of low concentration. In molasses, the high concentration of sugar outside of the cell membranes of the yeast/bacteria really wants to get into the low concentration area within the cell of the yeast and bacteria. This osmotic pressure will eventually draw the water out of the cell to balance the outside and inside concentrations, effectively killing the cell. But in cane juice, there isn't a high enough concentration of sugar to do this. In fact, its the perfect concentration of sugar to facilitate bacteria and yeast growth. So without heavy processing (read: drawing off water to form a syrup), it is useless. A sugar jack, however, is using a non-waste ingredient. It's taking the refined sugar, either white table sugar or refined brown sugar, and using it as a fermentation base. If you've seen Moonshiners, you've seen Tim hauling around big bags of sugar to supplement his corn fermentation. This is the main difference between a rum and a sugar jack: one uses a waste product, the other uses a finished product to achieve a high alcohol wash.
Do I think the TTB will open up a new category for sugar based moonshine-like products? No. Do I wish they would? Yeah. I think lumping it in as a rum is doing it a disservice. Even if it's not a 100% pure sugar wash, I still think there should be some wiggle room here. A 51/49% mix of corn to sugar doesn't really make a whiskey, nor does it make a rum. It makes an entirely different animal. But, hell, for all I know they could be classifying it as a vodka. The Standards of Identity for Distilled Spirits is a funny thing. And I spent months studying it.