It is amazing how this myth keeps popping up over and over again. Actually it is not restricted to Jack Daniel’s but this it is by far the most prominent example of a falsely alleged non-bourbon.
The myth comes in three flavours:
- “It is not a bourbon because it is from Tennessee”
- “It is not a bourbon because it is charcoal-filtered.”
- “It is not a bourbon because it does not say so on the label.”
Let’s see what the official US whisky regulations have to say about this:
§ 5.22 The standards of identity.
(1)(i) ‘‘Bourbon whisky’’, ‘‘rye whisky’’, ‘‘wheat whisky’’, ‘‘malt whisky’’, or ‘‘rye malt whisky’’ is whisky produced at not exceeding 160° proof from a fermented mash of not less than 51 percent corn, rye, wheat, malted barley, or malted rye grain, respectively, and stored at not more than 125° proof in charred new oak containers; and also includes mixtures of such whiskies of the same type.
There is no mention of a required geographic origin here. Bourbon is defined by its ingredients and its storage.
Regarding the filtration there is a subsection further down dealing with it:
§ 5.23 Alteration of class and type.
(b) Extractions. The removal from any distilled spirits of any constituents to such an extent that the product does not possess the taste, aroma, and characteristics generally attributed to that class or type of distilled spirits alters the class and type thereof, and the product shall be appropriately redesignated. In addition, in the case of straight whisky the removal of more than 15 percent of the fixed acids, or volatile acids, or esters, or soluble solids, or higher alcohols, or more than 25 percent of the soluble color, shall be deemed to alter the class or type thereof.
The regulations only state the the filtration must not be overdone, but nothing bourbon-specific can be found here either.
Jack Daniel’s – and also their Tennessee competitors George Dickel – point out their charcoal “mellowing” (also known as Lincoln County Process) as something that sets them apart from other whiskies. But the simple fact that there are also charcoal-filtered Kentucky bourbons like Jim Beam Choice disproves the Tennessee hypothesis.
And it should be pointed out that there is no requirement for an American whisky that meets the bourbon criteria to be labelled as bourbon. Jack Daniel’s and others choose not to do so because they want their whisky to appear as something different than the Kentucky bourbons. But in fact they are not.