TTB's Proposed Changes: Alcohol Labels to Feature Content, Allergen, and Nutrition Details

On January 17th, 2025, the Alcohol and Tobacco Tax and Trade Bureau (TTB) announced two major Notices of Proposed Rulemaking (NPRMs) aimed at transforming alcohol labeling regulations. These proposed changes seek to bring transparency to beverages falling under the FAA Act, such as certain wines, distilled spirits, and malt beverages by including alcohol content, nutritional information, and allergen declarations.

What's Being Proposed?

Alcohol Facts Labels: Notice No. 237

One NPRM introduces the concept of "Alcohol Facts," which would function similarly to the familiar "Nutrition Facts" on food products. This label would disclose:

• Alcohol Content: Measured in ounces of pure alcohol per serving, with a ±1% tolerance for products over 0.5% ABV.
• Nutrition Information: Including calories, protein, carbohydrates, and total fat with specific rounding rules and tolerances.
• Serving Size and Servings Per Container: Standardized serving sizes based on alcohol content

Labels would appear either as a detailed panel or linear text format, depending on the packaging. Importantly, this proposal allows for label changes without requiring a new Certificate of Label Approval (COLA), simplifying the compliance process for producers.

Allergen Declarations: Notice No. 238

The second NPRM focuses on safety and consumer awareness, mandating the disclosure of nine major allergens, including milk, eggs, peanuts, wheat, and sesame. This requirement would extend to malt beverages, distilled spirits, and most wines. Even incidental additives used during production, like processing aids, must be disclosed.

Exemptions and Special Cases

Not all products would be affected. Hard seltzers made without malted barley or hops and wines with <7% ABV fall under FDA jurisdiction and are exempt. Additionally, products that don’t cross state lines are excluded, though TTB may use its authority under the Internal Revenue Code to require alcohol content declarations on these beverages.

Timeline and Public Input

The TTB has proposed a phased implementation timeline of five years, giving producers ample time to comply. Additionally, the comment period for the proposed rules has been extended through August 15, 2025, allowing stakeholders more time to provide feedback and suggestions.

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