|Breakside Brewing's 1 barrel system|
To try to answer my first question what makes a brewery nano, I naturally have consulted the internets and found that the only official-ish reference to what a nano brewery is located on the good ole governmental page of the TTB in their Beer FAQs section:
B:10 What are the guidelines for a Nano brewery?
Nano-breweries, which we define as very small brewery operations, are springing up across the country. Nano brewing is a result of the steady appeal for craft-brewed beers and the beneficiary of the growing home brewing movement. We issue this advisory as a reminder that any beer produced for sale by home brewers is not exempt from Federal excise tax payment.
Section 5092 of the Internal Revenue Code of 1986 (IRC) defines a brewer as a person who brews beer or produces beer for sale. Section 5053(e) of the IRC provides an exemption from Federal excise tax payment for beer that is produced for personal or family use.
Pursuant to § 5053(e) any adult may, without payment of tax, produce beer for personal or family use and not for sale. The aggregate amount of beer exempt from tax under this subsection with respect to any household shall not exceed–
(1) 200 gallons per calendar year if there are 2 or more adults in such household, orFor purposes of this subsection, the term “adult” means an individual who has attained 18 years of age, or the minimum age (if any) established by law applicable in the locality in which the household is situated at which beer may be sold to individuals, whichever is greater.
(2) 100 gallons per calendar year if there is only 1 adult in such household.
Persons who produce beer for sale, no matter how small the amount, must qualify as a brewer under the provisions of 26 U.S.C. 5401. In addition to paying the Federal excise tax on any beer that is removed from the brewery for consumption or sale, consumer packages must contain the government health warning statement (see 27 CFR part 16). Further, the labeling and advertising provisions of the Federal Alcohol Administration Act, which are found at 27 U.S.C 205, may apply. Regulations implementing § 105, as they relate to malt beverages, are set forth in part 7 of the TTB regulations (27 CFR part 7), Labeling and Advertising of Malt Beverages.
If you have a question regarding whether your operation qualifies for the exemption as found in § 5053(e) or whether you need to complete the brewery qualification process pursuant to 26 U.S.C. 5401, please contact the TTB National Revenue Center at 1-877-882-3277 or e-mail at: firstname.lastname@example.org.
OK, we knew that the term nanobrewery naturally designates that a brewery is small, and according to the government, they are treated no different than a brewery of any other size regarding regulations. So, we still ask the question, is a 10 barrel brew house and 1000 barrel a year production "nano," or merely just small compared to other breweries? There are brewers out there using 1 barrel systems - should they be classified as "pico"? I know we can all agree that an operation that small is "nano," but where do we draw the line, and why is a line necessary to begin with?
To me, seeing brewers like Rogue jumping on the bandwagon of nanobreweries simply by hosting a beer fest - and to top it off, hosting the 2nd Nano fest just after the Nano Beer Fest started by Fanno Creek Brewing in Tigard, OR - suggests that the marketing department has jumped on this as a buzz term. Consulting the website for the Fanno Creek Nano Beer Fest, no explanation is offered for what constitutes a nanobrewery. It has been pointed out that the festival featured breweries such as Fort George (30 bbl system), Oakshire (15 bbl system, about 3600 barrels expected output for 2010), Pelican (15 bbl system, about 1500 barrels a year) that are still relatively small, but most would not consider to be "nano." I noticed a facebook post from tiny local brewer Natian Brewery showing some unhapiness at the fact that larger brewers were being marketed as Nano:
I contacted Natian Head Brewer/Owner Ian McGuinness to elaborate on his thoughts and what the definition of a nanobrewery was:
Natian Brewery I am seeing some MICRO breweries throwing around the term "nano" when describing themselves. When a micro brewery trys to steal the "Nano" thunder from us tiny guys, it's the same as Budweiser coming out with "craft" recipes and the like. For shame, I say, for shame.....
"Being that there is no "definition" of Nano, as in, federal/state hasn't given it a production number or financial gains number to define this category, I will hold off trying to quantify this response. But one can look at current classifications in the brewing industry and realize that it has nothing to do with brewery size but actual annual production that constitutes the way a brewery is classified by industry regulators.
But I think this un-official (nano) classification has been brought on by the industry "patrons" not by the industry regulators. So it totally means something more than mere numbers or annual production. Nano is in essence the embodiment of "mom & pop" brewing."
Now let's take Rogue/Green Dragon's Nano Fest. They have at least set out some guidelines for what should be the cutoff point. They state that nanobreweries are limited to breweries who produce less than 996 barrels per year. That is just about how much Upright Brewing produced last year but will greatly exceed next. I tried to get ahold of a Rogue representative to figure out how they came up with this number, but I have received no responses. As far as I can tell, it is a figure based on their own restrictions, and not an actual definition of a nanobrewery.
While I find it refreshing that Rogue/Green Dragon has put some qualifications on what constitutes a nanobrewery, as well as showcasing them at their own establishment, it still reeks a bit of marketing to me. This point is amplified by the fact that they started the festival just prior to Fanno Creek's fest, an actual nanobrewery by most peoples' definition, and have confused consumers by essentially using the exact same name (Fanno Creek's is titled Nano Beer Fest while Rogue's is titled Nano Fest simply taking out the word "Beer").
Brewpublic has done an admirable job of taking the word nano out of the equation in their Microhopic events that are dedicated to showcasing both brand new and small brewers. Without using the buzz terms, Brewpublic has instead focused on promoting the mom & pop or "micro" brewers for their products alone.
An excellent and varied selection will be showcased at Microhopic 2 at Bailey's Taproom on 9/8.
To me, when I hear people going on about a brewery being "nano," it is a huge turnoff. I support the small, the local, the "mom & pop" as much or more than anyone, but I will be the first to say that none of that matters when it comes down to the beer itself. If we as beer geeks and consumers are going to turn our noses up at the big boys even when they put out a solid beer, then I think there may be something wrong with the craft industry. I'd say it's about promoting quality over anything else, size included. It is not infrequently that I hear people bemoaning Widmer for their Hefeweizen, but some of these same people have never tried many of the incredible beers Widmer makes for the Gasthaus and the Brothers Reserve series.
Let me be clear: I think some of the newest and smallest brewers in town, like Breakside and Coalition, are making some great beers and deserve all the attention they can get, but you won't see me promoting Tugboat or Captured By Porches anytime soon.
Ian Mcguinness objected to my thoughts a bit and offers this contrary opinion:
"Just remember one thing when you want to take size of a brewery out of the equation. Size makes a world of difference, maybe not to someone sitting down at a bar ordering a pint, but it is all the difference to the brewery. Budweiser has the BEST - ABSOLUTE BEST quality program in the industry, if not the entire beverage manufacturing world. Are they your favorite beer? Are you interested in other aspects of your pint as well? Locality, genuene interest from the brewer who made it for you, the story and love behind that pint? In other words, would you rather buy small and local or big and mainstream? It's the difference as going to the farmers market or going to Wal-Mart for your food."
|Natian Brewery's 1.3 barrel system|
I will say this, Ian. If I am looking for a cup of coffee and there is a Starbucks (not great quality but dependable) in front of me and next to them is a Mom & Pop of the same quality, I will go to the Mom & Pop. But if there is some random shop with some unknown blend of questionable quality, I will march straight into that Starbucks.
It has occured to me that Brewpublic has hit on something that we have forgotten about. We used to call the craft brewers "microbreweries". That term is still used in corporate restaurants everywhere, but has long been a banished term by the industry since the "micros" became so prevalent, and instead we now call them "craft breweries". I like the term "Craft Beer" and I think it is good for the industry to get out of the shadow of being "micro," but perhaps this calls for a return to the use of "micro" for the little guys?
I encourage everyone to support the "micros". We need them, but let's not make this a buzz word like "barrel-aged". Lastly I leave you with a few more words from Ian:
"I argue that in this ever expanding industry, more categories need to be created to reflect the many different breweries in our country. We are living in a new age of beer brewing in America but stuck in the industry language of the past where only 6 breweries rule supreme."