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Disclosing Allergens on Beer Labels

January 8, 2016

As more fully discussed on the TTB website, current regulations under the Federal Alcohol Administration Act do not require the disclosure of major food allergens on alcohol beverage labels. However, the TTB has published an interim rule which sets forth standards for optional allergen labeling statements.  Under the interim rule, producers, bottlers, and importers may declare the presence of major food allergens in their products, but are not required to do so.

However, if an industry member chooses to undertake any allergen labeling, the label must comply with the labeling standards specified in the interim rule.  If any one major food allergen is declared, all major food allergens used in the production of the alcohol beverage, including major food allergens used as fining or processing agents, must be listed.

If you decide to disclose allergens, an allergen declaration must consist of the word “Contains” followed by a colon and the name of the food source from which each major food allergen is derived. For example, a declaration could be “Contains: milk and egg.” If any one major food allergen is declared, all major food allergens used in the production of the alcohol beverage, including major food allergens used as fining or processing agents, must be listed.

Consistent with the provisions of the Food Allergen Labeling and Consumer Protection Act of 2004, FALCPA, the interim rule defines a “major food allergen” to mean any of the following: milk, egg, fish (for example, bass, flounder, or cod), Crustacean shellfish (for example, crab, lobster, or shrimp), tree nuts (for example, almonds, pecans, or walnuts), wheat, peanuts and soybeans, as well as any food ingredient that contains protein derived from one of these food sources.  In the case of a tree nut, the name must be listed as the specific type of nut (for example, almonds, pecans, or walnuts). In the case of Crustacean shellfish, the name must be listed as the species of Crustacean shellfish (for example, crab, lobster, or shrimp). In the case of fish, the species is not listed; the allergen is listed simply as “fish.” The terms “egg” and “peanuts”, as well as the names of the different types of tree nuts, may be expressed in either the singular or plural form. Furthermore, the term “soy,” “soybean,” or “soya” may be used instead of “soybeans.”

This additional information may be placed on any label affixed to the container. A major food allergen declaration should be readily legible under ordinary conditions and on a contrasting background.

I think within the next few years the labeling of major food allergens will be a requirement.  We shall see…

Cheers.

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