USA: TTB Proposes Comprehensive Labeling Regulations for Alcohol Beverages

The Alcohol and Tobacco Tax and Trade Bureau (TTB) has announced two proposed rulemakings that could revolutionize the labeling of alcohol beverages, including beer and malt beverages. These proposals, published on January 17, 2025, mandate the inclusion of comprehensive nutritional, allergen, and alcohol content information under new "Alcohol Facts" labels.

Key provisions include mandatory disclosures of serving size, alcohol content, calorie count, and nutrient composition (carbohydrates, fat, and protein). Labels must also identify any of the nine major allergens, such as wheat or peanuts, even when used as processing aids. Serving size standards differ by alcohol content, with 12 ounces for beers below 7% ABV and 5 ounces for those above.

One innovative aspect is the requirement to specify the amount of pure alcohol per serving. For example, beer labels must now indicate alcohol content rounded to the nearest tenth of a percent, with strict tolerances for accuracy. These rules would also apply to keg labels and beverages not crossing state lines, extending TTB's reach under federal authority.

The proposals, stemming from a 2022 Treasury report recommending enhanced competition and consumer transparency, reflect years of advocacy from consumer groups and trade associations. Despite broad industry input, the Brewers Association has criticized the omission of QR code-based disclosures, arguing the changes disproportionately burden smaller brewers. TTB offers a five-year transition period for compliance, allowing producers to exhaust existing inventories.

Public comments are invited until April 17, 2025, offering stakeholders an opportunity to shape the final regulations.

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