What TTB label requirements are most often violated and how can you avoid errors on your distilled spirits labels? Let`s take a look! (e) Alcohol-free. The term `non-alcoholic` may be used on the labels of malt drinks only if the words `less than 0,5 % by volume (or 0,5 %) alcohol content` appear immediately next to it, in legible inscription and on a completely contrasting background. Tolerances are not allowed for malted beverages labelled as “non-alcoholic” and containing less than 0.5% by volume of alcohol. A malt beverage shall not be labelled with an alcohol content of 0,0 % by volume of alcohol unless it is also labelled as `non-alcoholic` in accordance with point (f) of this Section and does not contain alcohol. (c) notification obligations. For electronic filing, the importer must submit to U.S. Customs and Border Protection (CBP) at the time of filing the customs declaration the valid COLA TTB identification number that corresponds to the label on the product or the quantity of malted beverages imported. If the importer does not submit an electronic submission, they must provide CBP with a copy of the COLA at the time of registration. In addition, at the request of the competent official of the TTB or a customs officer, the importer must provide a copy of the applicable cola and, where applicable, proof of the authorization of the holder of the cola. TTB makes a corresponding amendment to the existing § 5.32, so that the net Content Start Printed Page 18715 can appear on any label.
TTB also amends the definition of the term “mark marking” in existing § 5.11 to remove the requirement that the mark must be the primary display field. To clarify, this means that the brand label can be on any side of the distilled spirits bottles, but must have the brand name, class and type designation, and alcohol content in the same field of view. This Part sets out the requirements for the labelling and packaging of malt beverages in containers, including label approval requirements and rules for mandatory, regulated and prohibited labelling declarations. This Part also sets out the requirements that apply to the advertising of malt-based beverages. 1. The indication of alcoholic strength by volume shall be expressed as a percentage by volume of alcohol. Other true, accurate and specific factual representations of alcohol content, such as alcohol by weight, may be made as long as they appear with and as part of the indication of alcohol content as a percentage of alcohol by volume. (2) Similar State law. For the purposes of this section, a “similar” state law may be found in state laws or regulations that apply specifically to malt beverages, or in state laws or regulations that contain general labeling requirements that are not specific to malt beverages but apply to malt beverages. To be “similar” to the requirements of the confederacy, the requirements of the states do not need to be identical to the requirements of the federal government. However, if the label in question does not violate the laws or regulations of the state or states to which the brewer, wholesaler or importer ships the malt beverages, it does not violate that part.
TTB received 11 comments in support of the creation of the “agave spirits” class, including several distillers, the Missouri Craft Distillers Guild, the Kentucky Distillers` Association, the American Craft Spirits Association, and the American Distilled Spirits Association. Some commentators suggested changes to the proposed standards, such as creating an additional type designation for products made from 100% agave or authorizing the use of agave syrup as a fermentable ingredient. The Tequila Regulatory Council (TRC) stated that it welcomed the proposed class, but suggested that tequila or mezcal should be required to use the terms “tequila” or “mezcal” on their labels if they meet the requirements of these standards. Most labelling requirements for distilled spirit drinks fall under the jurisdiction of the TTB. In 2016, the results of the ABSP were published. Since then, the office has focused on working directly with violators to correct errors and introduce policies that address the most common issues in spirits labeling. (a) health warning. Alcoholic beverages, including malt-based beverages containing at least 0.5% alcohol by volume, must be labelled with a health warning under the Alcoholic Beverage Labelling Act, 1988 (ABLA). Provisions relating to the implementation of ABLA are set out in Part 16 of 27 CFR. All alcoholic beverages containing more than 1.1% by volume of alcohol must indicate the alcohol content of the product. The alcohol content of the beverage must be declared x% vol or abbreviated to x% a|c/ vol.
The declaration must be displayed in the main display field. The display area includes all areas of the container except the top and bottom, that is, any area that is visible without having to rotate the container. In most cases, if you want to revise the label of the alcoholic beverage, you will need to submit a new certification application and wait for a COLA before using the new design on your products. However, some changes can be made without reapplying your label: (a) Application. The labelling practices, declarations and representations set out in this Subsection may only be used on the labels of malt beverages if they are used in accordance with this Subsection. In addition, if any of the practices, statements or representations in this subdivision are used elsewhere on containers or in packages, it must comply with the requirements of this subdivision. For the purposes of this subpart: The proposed Regulations should not imply that TTB would abandon its position of submitting to the FDA on issues of ingredient safety, safety of food contact materials, and adulteration under the FD&C Act. TTB continues to work with the FDA within our respective authorities on these issues and will continue to rely on the FDA to make decisions regarding ingredient safety and whether the use of certain ingredients distorts an alcoholic beverage under the FD&C Act. b) Other beers not produced with malted barley or hops. The provisions of this Part do not apply to beer products which are not manufactured with both malted barley and hops, or whose parts or products thereof or which for any other reason do not fall within the definition of a “malt beverage” in accordance with § 7.1.
Bottlers and importers of alcoholic beverages that do not fall within the definition of malt beverages, wine, or spirits distilled under the FAA Act should refer to applicable food labeling regulations issued by the U.S. Food and Drug Administration. See 21 CFR Part 101 (2) For malt beverages with an alcohol content greater than 6% by volume (determined without regard to any tolerance otherwise permitted under this Part), no more than 1.5% of the volume of the malt beverage shall consist of alcohol obtained from beverage-free added flavourings and other beverage-free alcoholic ingredients. TTB monitors the promotion of alcoholic beverages through a combination of: Imagine this scenario. You buy a bottle of wine that doesn`t have a label. The wine looks alcohol-free. A drink later, you`re so drunk that you can barely walk. You would definitely have ignored the bottle of wine if you had known it wasn`t alcohol-free. This is just one scenario that explains why it is important to label the alcohol content in alcoholic beverages.
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