Our pals at the Alcohol and Tobacco Tax and Trade Bureau (TTB) sent a handy list of the most common errors they see in label approvals. If you want to speed up the label approval process for your malt beverages, pay close attention to these common missteps and follow these tips. If you have more questions or just really love talking bureaucracy, the TTB will present its TTB Bootcamp for Brewers at the Craft Brewers Conference on Sept. 9.
Incorrect class/type designation on formula-exempt products. TTB Ruling 2015-1 exempts from formula approval malt beverages made with certain ingredients and processes (See Attachment 1). The ruling states that the label for such products must include a class/type designation that is in accordance with trade understanding of the product. Such designations must include the base product, such as “malt beverage,” “beer,” “ale,” etc., together with a modifier or explanation that provides the consumer with adequate information about the fruit, spice, honey, or other food ingredient used in the beer.
Tip: For information on the proper way to designate formula-exempt products, review Attachment 2 for examples of adequate and inadequate class/type designations.
Formula Approval is required. TTB regulations and guidance require formula approval for certain beers/malt beverages. When we require a formula approval, you must obtain it before you apply for label approval.
Tip: If you don’t know if your product requires TTB formula approval, use our online tool, Which Alcohol Beverages Require Formula Approval?, or review TTB G 2016-1A.
Net contents stated incorrectly. TTB regulations include specific requirements for how the mandatory net contents statement must appear on your label. For example, the net contents must be stated in standard U.S. measure but the equivalent metric measure may also be stated.
Tip: Use this chart to determine the correct format for your net contents statements: