The Labeling requirements for craft beer are obscure and complex as you’ve got to satisfy State guidelines and cross-check the requirements of U.S. Customs and FDA for important label statements. And not following these regulations will result in your product being labeled as misbranded and result in a loss of profit and reputation.
That’s why we’ve created an easy-to-understand craft beer TTB labeling requirement guide. Here’s what the article covers:
Let’s start with the legal definitions.
Here are some legal definitions of terms to avoid confusion.
TTB: The Alcohol and Tobacco Tax and Trade Bureau. It operates under the Department of Treasury and regulates and collects taxes on trade and imports of alcohol, tobacco, and firearms within the United States.
Brand Label: The label containing the brand name of the malt beverage.
Certificate Of Label Approval (COLA): A TTB-issued certificate that authorizes the production and distribution of bottled wine, distilled spirits, and malt beverages within the USA, or the removal of the beverage from Customs Custody to be introduced into Commerce.
Malt Beverage: Any alcoholic beverage made by fermenting malted barley with hops or any of their parts or products. This definition also includes beverages containing malted or unmalted cereals or other carbohydrates and products prepared from them.
Prohibited Statement: Containers of malt beverages, their labels, or any carton, case, or individual container coverings, used for sale at retail, or any written, printed, graphic, or other material accompanying such containers to the consumer must not contain statements stated in section 7.29
Misbranded Product: A product is termed misbranded if:
Container: Any closed receptacle of any size holding the malt beverage.
Bottler: Anyone who places malt beverages in containers that are one gallon or less.
Packer: Anyone who places malt beverages in containers more than one gallon.
All craft beer labels must have the following label statements to be following TTB regulations.
The Brand name is the name you used to market your beer, and it mustn’t inaccurately depict the origin, age, identity, or other product characteristics.
Note: If your bottle doesn’t contain a brand name, then the name of the bottler or packer is considered the brand name.
The class and type tell the consumer what type of malt beverage the container has. It can be general (malt beverage), specific (pale ale), or very specific (Indian pale ale.)
While some names are sufficient as the class and type, other names like “malt beverage specialty” require a product name that reflects the composition and product character.
Some beers like Bavarian, Wurtzburger, Weiner, etc., produced outside of Germany, Vienna, or Austria also require the word “type” or “American” or other adjective statement indicating like “Brewed in the U.S.” to indicate the place of production.
Domestic malt beverages must state the bottler or packer’s name and the place where the beer was bottled and packed. You may also use the principal place of business as long as a TTB officer determines that the address will not mislead consumers about the beer’s origins.
If your beer is imported, then the words “Imported by” should precede the name of the permitted importer, exclusive agent, or sole distributor, or another person responsible for import, along with the said person’s principal place of business. You needn’t include the name or place of the foreign manufacturer, packer, or shipper unless the State or foreign law requires it.
You needn’t state the alcoholic content on your label unless the State law requires it. If the state law doesn’t specify how the alcoholic content must be stated, you must use percentage by weight or volume to specify it.
For usage of terms like non-alcohol, or low alcohol, check out the table below:
The Net Contents statement is the amount of beer contained in each container. Check out the following table to see how the net contents must be stated on the label:
You must declare the following statements on your brand label or on a separate label (back or front)
Here are some general labeling requirements your labels should follow:
Type Size: The following table gives the size of the required label statements (including the alcoholic content statement) regardless of the font type used (serif, sans-serif, script, and display.)
If the label has descriptive or explanatory statements, the label statements should be substantially more conspicuous than the descriptive or explanatory statements. For containers less than 1 pint, the type size for alcoholic content varies according to the table below:
The TTB labeling requirements for beer are complex as you need to cross-reference state guidelines and the labeling requirements from other departments like the FDA and U.S. Customs.
To make the ordeal easier and ensure you don’t end up with a misbranded product, you can create a compliance checklist and a workflow process your team must follow on an intuitive label management software like Artwork Flow. We’ve even got a 14-Day FREE Trial, so check out the software and get started!