What does every brewer or distiller interested in commercializing flavored alcoholic beverages for the U.S. market have in common? They need federal government approval of their beverage formulas. So, whether you’re an R&D team creating innovative flavors for a beer brand, or a start-up with a fresh take on hard seltzer, you’ll soon need to connect with the TTB.
What is the TTB?
The TTB, or Alcohol and Tobacco Tax and Trade Bureau, is a government agency with broad oversight. The TTB collects taxes but also monitors the labeling, advertising, and marketing of alcohol, tobacco, firearms, and ammunition. The TTB's mission focuses on administering laws and regulations to protect consumers by ensuring “only qualified persons engage in the alcohol beverage industry” (TTB).
The TTB must review and approve certain ingredients in alcoholic beverages, including added flavors, for several reasons:
- To confirm that ingredients comply with federal requirements and are considered safe.
- To assign the correct tax classification.
- To ensure labels provide non-misleading information about the beverage.
Read on to learn more about navigating the process for TTB approved ingredients.
Which Beverages Must be TTB Approved?
The TTB oversees the commercialization and proper labeling of alcoholic beverages, including
- Malt beverages
- Distilled spirits
- Hard seltzers, both malt-based and sugar-derived
The TTB Approval Process
Before starting production, alcoholic beverage manufacturers must apply for a TTB permit to operate their brewery or distillery. The free application process may be lengthy, taking up to 120 days for approval.
After receiving the permit, most manufacturers must submit their beverage formulas and pertinent information on certain added ingredients. In addition to evaluating the beverage ingredients, the TTB will consider the production process before approving scale-up.
The final step manufacturers will take before producing brewed or distilled beverages is submitting package labels. Here are a few examples of approved labels:
TTB Regulations and Formula Requirements
When developing any alcoholic beverage for retail sale that uses a non-traditional process, brewers and distillers must send a formula to the TTB before beginning production. The formula is a complete list of ingredients and the step-by-step process used to make the final product.
If a brewer or distiller uses one of the following traditional processes, the TTB doesn’t require a formula submission:
- Filtration before bottling
- Filtration instead of pasteurization
- Centrifuging for clarity
Non-traditional processes (which require a submitted formula) include:
- Removal of any volume of water from beer
- Filtration of beer to substantially change the color, flavor, or character
- Separation of beer into different components
- Reverse osmosis
- Addition of flavor ingredients
- Concentration of beer
- Ion exchange treatments
A formula application must include a Flavor Ingredient Data Sheet (FIDS) with submission.
FIDS show the following information about the flavor:
- the manufacturer
- the flavor name and the required drawback number for the TTB
- the alcohol content
- the natural or artificial designation
- maximum usage rate based off the limited ingredients the flavor may contain such as caffeine, vanillin, propylene glycol, maltol, and preservatives.
Formula applications may also require the following:
- Laboratory analysis- Most imported products containing more than 7% alcohol, alcohol-free malt beverages, and case-by-case submissions require laboratory analysis. Samples are processed before formula applications can be approved.
- Ingredient Specification Sheets (SPEC)- A SPEC is required with a formula submission when an ingredient added to the beverage contains more than one component. For example, a vintner adding fruit juice to sweeten wine would need a SPEC sheet listing the fruits that compose it.
TTB Approval for Low/No Alcohol Beers/Malt Beverages
With interest in no and low-alcohol offerings growing, many alcohol developers are exploring the emerging category. And some are wondering who provides oversight—the TTB or the FDA?
The Food and Drug Administration (FDA) monitors compliance for most NA beverage offerings (those under 0.5% ABV). If you’re formulating malt beverages or de-alcoholized drinks, however, you must interact with the TTB.
- Before production, developers of malt-based drinks containing less than 0.5% ABV (cereal beverages) must submit laboratory testing results to the TTB.
- If the production process removes alcohol from beer (de-alcoholization) to develop an alcohol-free offering, brands must follow the TTB’s labeling and advertising regulations (See 27 CFR 7.71).
If your launch falls under FDA purview, the finished drink requires a complete ingredient list and nutritional facts label, like any other non-alcoholic beverage.
Ingredients Used to Impart Flavor
From whole ingredients to extracts and flavors, many substances can impart exciting tastes to alcoholic beverages. For example, wheat beers might contain essential oils from citrus fruits like oranges to give a shandy-like experience. A wide array of beer and distilled spirit styles, such as cherry stouts, lime vodka, cinnamon whiskey, or coffee java porters, incorporate flavors to deliver the desired profile.
Why consider adding flavors during the brewing or distilling process?
- Consistency: Achieve a consistent and repeatable flavor profile for your finished good
- Customization: Craft your unique and preferred flavor profile precisely to your needs
- Ease of Use: Avoid the shipping, storage, and production challenges associated with using the whole ingredients
- Efficiency: Save time on labor by leveraging a highly concentrated ingredient
Although flavor ingredients in alcoholic beverages need TTB approval, speeding the development process is possible by partnering with companies that already have TTB-approved flavors because:
- Flavor manufacturers often have extensive libraries of liquid TTB-approved flavors to jumpstart your innovation process.
- You’ll gain easy access to the Flavor Ingredients Data Sheet (FIDS), a spreadsheet file that includes information about certain ingredients used in compound flavors.
- Flavor samples and the FIDS, including the maximum usage rate details, make it easier to develop batches of beverages that adhere to the TTB guidelines.
Trending Flavors Across Alcohol Categories
Are you ready to reap the benefits of incorporating flavor in your next alcohol innovation? Insights from recent product introductions can identify flavors that fit with your alcoholic beverage segment or inspire new ideas. We explored recent North American launches across top alcohol sub-categories to understand what’s trending. Across the landscape, we found fruit flavors are overwhelmingly popular (which aligns with our recent proprietary research on alcohol-free flavors, too.)
Let’s review the flavors that are growing or emerging in North America by top sub-categories using Mintel’s Global New Products Database details from the past three years:
- Peach (+200%)
- Pineapple (Launched for the first time in three years in 2022)
- Tropical (Launched for the first time in three years in 2022)
- Grapefruit (+50%)
- Passionfruit (+50%)
- Peanut Butter (+100%)
Flavored Alcoholic Beverages:
- Margarita (+166%)
- Watermelon (+100%)
- Pink Lemonade (+300%)
- Peanut Butter (+300%)
- Cinnamon & Peach (Launched for the first time in three years in 2022)
- Hot Honey (Launched for the first time in three years in 2022)
- Irish Cream (+166%)
- Coffee (+150%)
- Cherry (Launched twice for the first time in three years in 2022)
TTB Approved Flavors from FlavorSum Help You Navigate the Regulatory Process
Introducing new flavors for your alcoholic (or no-alc) beverage brand is an exciting way to create connections with your consumers. The federal government's regulations and requirements can make the launch process seem overwhelming. That's why choosing a trustworthy flavor partner that understands TTB guidelines and provides quick solutions is vital to a successful launch. By partnering with FlavorSum, you’ll gain access to a team of experts to support getting your new alcoholic launch across the finish line. Contact our team to learn more!