One of the first steps to getting your beverage alcohol brand on the shelf in the United States is to submit a Certificate of Label Approval, commonly known as a COLA, to the Alcohol and Tobacco Tax and Trade Bureau (TTB).
As a part of that process, some types of alcohol products—typically those with flavoring or coloring added—will need to submit a beverage formula for analysis along with the product. In requiring this step, the agency is primarily looking to identify non-traditional methods or ingredients, verify said ingredients meet the US Food and Drug Administration’s safety requirements for human consumption, and to better understand the product’s makeup for labeling and tax purposes. Although the average consumer likely doesn’t care how their bubbly wine is made, the TTB needs clarification between carbonated wine and sparkling wine because they are recognized as two different class types, with different labeling and tax implications.
Continue reading or watch the video below for an overview of what you need to know about formula approvals as a supplier in the U.S.
When is a TTB Formula Approval Required?
The fastest and most effective way to check to see if your product needs formula approval before it can be sold in the US is to visit the TTB’s website called “Do I Need A Beverage Formula.” You can learn more by clicking here to visit the site. If your product does require a formula, the TTB website will also tell you if you’ll need to send a sample for lab analysis.
What Information is Needed for TTB Beverage Formula Approval?
- Complete list of ingredients
- Method of manufacture – a description of the steps taken to create the product
- Final ABV amount per batch – If each batch will have varying alcohol content, it needs to be stated clearly in the formula.
- Specification Sheet – covers coloring ingredients, juice concentrates, or extracts produced in-house by the producer.
- Flavor Ingredient Data Sheet – a document for any flavors produced by a third-party producer. It is highly recommended flavor producer has pre-existing TTB approved flavors prior to being listed in the formula.
Once you’ve completed your formula document, we recommend reviewing the TTB’s list of most common errors and the Top 10 reasons for formula rejections before submitting it.
What is the TTB Formula Approval Time?
The TTB has a webpage that shows the current wait time for formula approval processing. Currently, the average is 4 days for spirits, malt, and wine formulas and 16 days for formulas that require a sample analysis.
For the most up-to-date processing times, visit the TTB Processing Times webpage.
What happens after your formula is approved?
Once the formula is approved, it is valid for 10 years. It will be associated with two ID numbers: the Submission ID and TTB Formula ID, which are linked to the COLA application. When that 10-year period is up, the formula will need to be renewed. If there are no changes, you can file a superseding formula application.
We’ve covered a lot above, but you still may have questions. Here are some related questions and answers that you might still have.
Is Alcohol FDA Approved?
No, alcoholic beverages are not FDA approved.
What does TTB Mean?
TTB stands for the Alcohol and Tobacco Tax and Trade Bureau (TTB).
What does TTB approved mean?
TTB approved means that the Alcohol Tax & Trade Bureau (TTB) has approved the flavor composition of your alcoholic beverage.
Conclusion
In closing, just a simple reminder that your alcoholic beverage will need to meet all formula requirements in order to obtain approval. That approval process applies to malt beverages, distilled spirits, and more. It wouldn’t hurt to work with an alcohol formula lawyer if you’re unsure or you can reach out to us and we’re happy to help guide you in the right direction.
Have more questions on formulas? Reach out to us at info@parkstreet.com.