For my entire importing career my focus was on wine, including sparkling and fortified which have some unique characteristics when it comes to labeling and licensing. But these are basically minor variations on standard wine principles. When I started submitted malt beverage labels to TTB for approval for clients, it opened up a whole new world of US labeling requirements.
Let’s face it, I’m a geek when it comes to this stuff. I really do love knowledge, even when it involves Alcohol Tobacco Tax and Trade Bureau regulations for US compliant labels! I had no idea that almost all the rules were different and in my nascent malt beverage label submission journey I was on a first name basis with the TTB agents I spoke to on a regular basis.
Here are some of the requirements you won’t find on wine labels:
- All net contents must be in US measurements, e.g. “1 pint 9.4 fluid oz”
- Non-alcoholic beers do not require label approval but they do require formula approval.
- Alcoholic beer requires label approval no matter what ABV (it is not required for wine below 7% ABV)
Ingredients must be listed. Some of them are approved as additives and some are not. There is an entire list of approved ingredients that include items like huckleberries, kale, grains of paradise, galangal root, Padang cassia and elder flowers. There are other ingredients that are considered by the FDA as GRAS (generally regarded as safe) which doesn’t sound terribly reassuring, nor particularly appetizing. I’m not at all sure what they would add to the beer either, other than roughage. This is only a fragment of that esoteric list:
- Oak cork
- Maidenhair fern
- Blessed thistle
- Iceland moss
- Buckbean leaves
- Simaruba bark
- Virginia snakeroot
- Angola weed
I discovered recently that TTB will not approve, without a detailed formula, items like Malagueta pepper or just “spices”. They will allow pepper, black or white, but required an explanation of “pink pepper” and honey ale is fine but they recently balked at “honey of Sicilian Black Bee”. It does allow tea, but not kombucha.
Many beer label issues share a commonality with wine, such as the government warning and a defined class of alcohol, e.g. red wine or Shiraz for wine and ale or Belgian-style ale for beer. But the differences define the procedure. With TTB, there is no “close enough”; it is correct or incorrect, approved or rejected.
The craft beer industry has exploded in the past few years and along with it, pushing the envelope on fermentation processes and innovative ingredients, which is great for the consumer but a bit of a minefield for COLAs (Certificate of Label Approval). In my 25 year importing career I’ve never had to submit a formula for a wine. In the past year, I’ve submitted three for beers. TTB is constantly updating their “approved ingredients and processes” lists as the agency sees what has become mainstream, but it is moving too fast. So for now, formulas, detailed explanations and reworking foreign labels to comply are the norm.
* * *
The steampunk labels in this post are some of my favorites. Used by permission of the brand and the artist.
Malt Beverage Brand: Della Granda | Label Artwork: Fabio Garigliano