Two Roads Brewing Company

more shenanigans from Two Roads, LOL. If only they made better beer......

 

Done.

Here's the text of my email:

Dear Two Roads,
First of all, let me say how very happy I am to have another top-quality brewery in CT. Your facility is incredible, many of your beers excellent, and your impact on the region wonderfully positive. Keep up the great work!
I do have one concern with your tasting room policies, however, namely your insistance that any non-Two Roads growler be slapped with a large Two Roads sticker. While I understand your (laudable) desire to increase the visibility of your brand, as well as the benefit you clearly see in obscuring your competitors' branding (a less laudable aim, imo, but an understandable one), you should know that this policy is troubling to me and many other beer enthusiasts.
Why force your customers to undergo the annoyance of peeling off a sticker and scrubbing the adhesive off their growlers? I planned to buy a growler of your fine Saison the last time I visited, but upon hearing that you planned to deface my favorite growler (one that I've been using and reusing for years, and hope to keep for years to come) I opted not to buy any beer to go at all. Continuing this policy will continue to lose my business, and likely that of others who share my concern.
Perhaps you could switch to easily-removable hanging tags to go around growlers' necks, or at the very least you could make the sticker an optional accessory rather than a precondition for a fill.

 

I got this email in response, apparently it is a CT law:

He also included the actual laws:

 

Well now the bashing can simmer down a bit. Bill is going to have to turn in his law degree.

 

If Two roads is pre-filling growlers, then yes the federal mandates are in effect, however per

http://www.ttb.gov/beer/beer-faqs.shtml#b9

"When is a growler a “large glass?”
A growler is a large glass when a consumer uses the container to make a purchase and the brewer then fills the container. Consumers may furnish their own growler or may purchase it from the brewer.

What are the requirements for the government warning label?
The Alcoholic Beverage Labeling Act (ABLA) of 1998 applies to sealed containers the brewer offers for sale to consumers. The ABLA does not apply to glasses or containers a brewer uses to serve beer at the brewpub. These containers do not meet the definition for a sealed container in which an alcohol beverage is offered for sale to the public.
However, the law applies to any keg or serving tank from which the brewer dispenses beer to containers. The brewer must apply a government warning label to the keg or tank. The brewer must comply with 27 CFR Part 16 regardless of whether the public has view of the keg or tank.
The statement must comply with these conditions.
It must be legible under ordinary conditions, and on a contrasting background.
The words “GOVERNMENT WARNING” must be in capital letters and bold type. The rest of the statement may not appear in bold type.
The maximum number of characters per inch of the warning statement is 25. All characters, including both upper and lower case, must be a minimum 2 millimeters in size.

What are the requirements for growlers that are “glasses?”
When the brewer fills a growler at the tap at the brewpub, and not in advance of sale, we consider the growler as a large glass sold at retail. These growlers are not subject to Federal labeling requirements. Some States consider this bottling activity and regulate accordingly. Brewers should check with State authorities."

*** EDIT *** I am not sure about the state mandates, but two roads cited federal regulations

 

Just bring your own sharpie, and when they're done defacing your growler, write "sucks" under their logo. Feel free to let the bartender see it.

 

I'm not sure what to believe because if that's the law then I find it kind of odd that all the other CT breweries I've been to violate it and don't use any kind of hang tag/sticker on growlers without their logo. Hopefully at the very least they switch to a sticker that can be pulled off easily and is much smaller. It seems like they could fit all the info they say is required on a small strip that's like 3"x1" that they could stick on the top or back of the growler instead of over the existing logo. Also, I forgot I had a picture, here's what is looks like for those that are curious

 

I don't mind some of their beers, think some are pretty good, and think others stink. That said, just like in everything else this brewery does, they nickel and dime you for EVERYTHING. Yes, I know breweries are in business to make money, but do you have to charge for EVERYTHING? A sip to see if you like a beer and want to order a pint, $2 please! Charging noticably more for their beer at your own brewery than elsewhere within the state, a common practice there. This is just them trying to get free advertising by putting their add on your growler.

 

Its not the law for growler fills. You don't need a label as long as they aren't pre-filled.

 

As someone from a state where they don't allow fills at all except in the brewery's own growlers, I think you complainers here don't realize how good you have it.

 

I have a different interpretation of your legal postings. Essentially the regulation you posted says the state has the ability to enforce rules beyond what is mentioned. In particular, it says some states consider it bottling and regulate it accordingly. The CT commissioner responded by saying the guideline for labeling must fall within what is called for in the Federal regulation as it pertains to labeling. What he is saying is that CT wants the products labelled, and that labeling needs to fall with the Federal guidelines for content. It is not unusual for state statutes to default to terminology and conventions at the Federal level, so instead of reinventing the wheel CT decided that what previously existed suited the situation.

And for the record, I'm not a fan of the gigantic label. Hang tag would be fine and more respectful of their customers.

 

my local CT brewery just uses a hang tag and happily fills other brewery labeled growlers

 

There is nothing in the law that changes/challenges the definitions set by the Feds.

http://www.ct.gov/dcp/lib/dcp/pdf/liquor/liquor_bb_2006_for_web.pdf

All labeling laws are intended for selling pre-packaged beer by an establishment holding a permit, not private owned glass being filled at a brewery/brewpub (as long as the tap handle states what is being poured). I read the entire law and talked to a lawyer friend of mine for reference.

 

Cover your growler in blue painters tape
Let the put the sticker on that
Peel off tap and sticker
Drink your Two Roads beer from your favorite growler

 

Or just don't buy them, if it bothers you that much.....

 

True

 

If the "Bill" you cite refers to me, I'd just like to point out that I've never claimed to hold a J.D. I'm proud to hold multiple degrees, but none of them pertain to the law.

From what I heard back from Two Roads and what RMoeNay have posted, it seems like there's some significant confusion going on at the state level. The law as written does not seem to require labeling of customers' growlers, but when Two Roads inquired in order to confirm this, they seem to have been told otherwise for whatever reason.

I have no reason to doubt their veracity on this front, and just hope that they come up with a more convenient way of affixing the (arguably) necessary labeling information than their current stickers.

Until they do, I won't be filling any growlers there.

Cheers!

 

Agreed 100%.

While I understand why a brewery might not want to undersell their retail partners and therefore keep to-go prices solidly at MSRP, I see no reason why the Two Roads tasting room needs to operate MORE greedily than just about any beer bar in the state.

$6 pints of year-round low-ABV flagships?
$2 or $3 tasters?
No happy hour discounts?

I mean, if they're selling out at those prices then more power to them, but I've been pretty well turned off as a potential in-house customer. If I go to a brewery, I expect the opportunity to sample all of their beers either for free or for a reasonable price before deciding whether or not to buy anything to go; simply the opportunity to taste what they had available the last time I visited would have cost me well over $10.

Given the obvious cost savings that go along with economies of scale, it's really hard to swallow that the gigantic Two Roads both charges infinitely more for samples and substantially more for growler fills than relatively tiny NEBCO.

 

Now this is just plain smart!