This category is legally mandated in states where any lager stronger than 5 percent alcohol by volume cannot call itself a lager beer. There are a number commercial brands that have been created to fill this category, many of which do not have great merit from the connoisseur’s perspective. Many malt liquors achieve their greater alcoholic strength through the use of adjunct grains—corn or rice—that add little flavor. Some strong European lagers are forced to adopt this labeling moniker for the U.S. market.