I think you pull rules from Mexico ... not the US.
I ran out of post yesterday so I couldn't reply.
Also, Besado is a "MIXTO" ... so no need for NOM. I wonder if the company can get away with saying "from 100% agave with infusion".
The company states that FCD imported the tequila in (which they would be the one that has NOM) then distill with infusion of herbs, then bottles it for ISBG. So what is a problem with NOM? NONE! Again Besado is a MIXTO.
That is beside the point. If Besado is well accepted and sold, I care not 100% agave or not. NOM or no NOM ... doesn't matter. People are not going to not buy Besado because it doesn't have NOM. I didn't even know anything about it NOM and never looked for one till it was bought up yesterday.
Here what I found from reading:
Some tequilas are bottled outside Mexico using bulk Mexican mixto tequila as a base. These bottles may not show a NOM identifier, but if they do it means the source of the bulk product, not the bottler. These bulk brands are not always governed by the strict Mexican laws, although the USA recently signed an agreement with Mexico to control the adulteration of bulk tequila by US bottlers. But without the CRT's immediate oversight, it is possible mixto tequila bottled outside Mexico could be adulterated with other non-agave, non-tequila ingredients. To counter adulteration and counterfeiting, the CRT has set up offices in Washington, DC (for the US and Canada) and in Europe to cover the EU.
Tequila bottled outside Mexico will never be 100% agave: it will always be a mixto. Tequilas bottled in Mexico all have a small identifier showing 'envasado de origen."
