The Alcohol and Tobacco Tax and Trade Bureau (TTB) issued ruling 2014-4 regarding which ingredients and processes used in the production of beer are to be subjected to formula requirements. Don’t worry, this will be helpful.
In this ruling, TTB exempts malt beverages made with certain ingredients, such as honey, certain fruits, certain spices and certain food ingredients, from the formula requirements of 27 CFR 25.55. TTB has also determined that certain processes such as aging beer in barrels that were previously used in the production or storage of wine or distilled spirits do not require formula approval.
TTB Ruling 2014-4 is effective immediately. Brewers with applications pending in Formulas Online for exempted products may withdraw these applications and proceed immediately to obtaining label approval (if required). As they come up for processing, TTB will reject any remaining pending and all new formulas applications for exempted products indicating that no analysis of the formula is required.
For quick reference check out Exempt Ingredients and Processes Determined to be Traditional Under TTB Ruling 2014-4.
TTB regulation 27 CFR 25.55 provides that a brewer must submit a formula for approval by TTB when the brewer intends to produce any fermented product that will be treated by any processing, filtration or other method of manufacture that is not generally recognized as a traditional process in the production of a fermented beverage designated as “beer,” “ale,” “porter,” “stout,” “lager,” or “malt liquor.”
Examples provided in the regulations
Brewers must file a formula for a fermented product using any of the following non-traditional processes:
- 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;
- Concentration of beer; or
- Ion exchange treatments.
Brewers are NOT required to submit formulas for the following traditional processes:
- Filtration prior to bottling;
- Filtration in lieu of pasteurization;
- Centrifuging for clarity;
- Carbonation; or