Beer Label Confusion

Seems like @Samlover55 did what y'all are telling him to do, which is why he has a bottle to give away instead of an allergic reaction to deal with!

You're probably much more likely to run into beers with Brett in them (with no indication on the label) than OP is with grapes, no? I can see where the surprise comes from.

 

A more convenient way to find the relevant links is to start here:

https://www.brewersassociation.org/business-tools/marketing-advertising/label-approval-guidance/

Only about 3-4 artificial ingredients must be noted on the label, e.g., saccharin.

Also, IIRC, fermentation is part of the brewing process and grapes ferment. Including fruit during the fermentation period has been an optional part of brewing beer for years, e.g., fruit Lambics.

 

Lots of legalese to wade through:

https://www.ttb.gov/rulings/ttb-ruling-2015-1-malt-beverage-formulas.pdf

https://www.ttb.gov/rulings/ttb-ruling-2015-1-attachment-1.pdf

https://www.ttb.gov/rulings/ttb-ruling-2015-1-attachment-2.pdf

But this seems to be the applicable section (from pg. 10 of the first pdf of the actual Ruling- Ingredients and Processes Used in the Production of Beer Not Subject to Formula Requirements)


There are a few important guidelines with respect to whether TTB will consider that a designation in accordance with trade understanding adequately identifies the product in a non-misleading manner. A designation in accordance with trade understanding must include the designation of the base product (such as “malt beverage” or “beer” or “ale”). Furthermore, it must include enough information to make it clear that the product contains at least one of the ingredients exempted by this ruling. Thus, the label may either identify each fruit or spice or other ingredient (for example, “Blackberry and blueberry ale,” or “Cinnamon and allspice stout”), refer to them by category (“Fruit ale ” or “Flavored ale” or “Spiced stout”), or identify one ingredient that best identifies the product (“Blackberry ale” or “Cinnamon stout” ) in a manner that clearly distinguishes the product from a malt beverage, beer, ale, porter, stout, lager, or malt liquor that is not brewed or flavored with any of these ingredients. Thus, a designation such as “beer” or “stout” is not adequate.

 

No they're suggesting he do his homework before buying. That is why he wants to know what has to be on the label.

Since there is no required "ingredients list" on the label they are suggesting he has use other means of checking before buying rather than after if he wants to avoid spending money first.

 

"Azurel" was likely referring to beers brewed with sorgum or rice totally replacing barley malt, not used just as adjuncts. Those beers are not legally "malt beverages" under the FAA Act under which the TTB operates, and so they must be labeled according to the FDA's labeling requirements, including the listing of ingredients.

Classification of Brewed Products as “Beer” Under the Internal Revenue Code of 1986 and as “Malt Beverages” Under the Federal Alcohol Administration Act

...in order for a brewery product to fall within the definition of a “maltbeverage” under the FAA Act, it must be a fermented beverage made from both malted barley and hops, or their parts, or their products.

In cases where a brewery product ... fails to meet the definition of a “malt beverage” under the FAA Act, the product will be subject to ingredient and other labeling requirements administered by the U.S. Food and Drug Administration (FDA).

That ruling is why a non-barley malt "beer" like DFH Tweason'ale" has this label:

 

Looks like the warning is right on the bottle, "Life is Uncertain, Don't Sip!"

 

Pretty bizarre the brewer didn't mention it - I love beers that are combined with wine, or is this case fermented with red wine grapes - that's totally a selling point to me, why did they leave it off the label?

 

There's a lot of misinformation in this thread (@jesskidden excepted), but I guess I shouldn't be surprised. Under "Class Designation" on this handy PDF is the following statement:

"When a malt beverage is made with the addition of spices, fruit, honey, or natural flavors, it requires specific labeling to indicate the class designation. These malt beverages must be labeled with a statement of composition that reflects the base malt product and the added ingredients, unless otherwise known in the trade under a particular designation. Examples of statements of composition that you might see on malt beverage labels include "Premium malt beverage with natural flavors", "Ale fermented with spices", or "Belgian-style Wheat Ale brewed with natural flavors."

 

Attention all breweries-Tell me what is in your beer! Give me a story! Tell me how it was brewed!
No one is going to steal your 'secret' recipe for god's sake....

 

So now I'm confused. The TTB approved that Lagunitas label since it is used on the bottle and on the markets. and there is no mention of grapes according to the OP.

Something doesn't seem to compute here.

 

Personally kind of baffled why the legislatures chose to require ingredient listing for the non-malt beverages (hell even soft drinks do), but our precious beer does not

 

Lagunitas' COLA # 17083001000474 was entered under the designation of "CLASS/TYPE 902 - ALE" (as were two previously keg labels COLA), so how would the TTB know it contained grapes, since the label itself doesn't note it and a formula was no longer required due to Ruling 2015-1.

Previously, such beers with "exempt" ingredients fell under "#906 - MALT BEVERAGES SPECIALITIES - FLAVORED". I can't figure out, given the 2015 Ruling, if Lagunitas made the error or did the TTB.

 

Sounding more and more like both.

 

And the COLA for that label states:
"CLASS/TYPE DESCRIPTION
MALT BEVERAGES SPECIALITIES - FLAVORED"

Confusingly, the keg label was:
"CLASS/TYPE DESCRIPTION
ALE"

 

Unfortunately label requirements are not that simple. The TTB manages this area and one link that does provide a place to learn more is below. Many flavorings & adjuncts do not require any label or formula.

Which Alcohol Beverages Require Formula Approval?
https://www.ttb.gov/formulation/do-I-need-a-formula.shtml

 

Since the label reads "Sour Ale," perhaps it was approved by the TTB as referred to by category; the lacto (or whichtever souring ingredient) was the defining characteristic rather than the grapes. I agree that the grapes should have been mentioned, but I can see how it got approval without.

I'm of the opinion that every label should have a small area by the govt warning for listing which malts, hops, and flavorings were used; the yeast or bacteria if it's notable. I've seen enough examples of it done right from different breweries to believe this is feasible for every beer, even if the brewery wants a clean graphic design without much text.

 

The TTB doesn't have a "Sour Ale" Class or Type for beer, recognized "Types" can be found at: https://www.ttb.gov/beer/bam/chapter4.pdf

COLAs are catagorized only by Class:
900 MALT BEVERAGES
901 BEER
902 ALE
903 MALT LIQUOR
904 STOUT
905 PORTER
906 MALT BEVERAGES SPECIALITIES - FLAVORED
907 CEREAL BEVERAGES - NEAR BEER (NON ALCOHOLIC)
909 OTHER MALT BEVERAGES (BEER)

The "950's" apparently used for Imports
950 MALT BEVERAGES
951 BEER
952 ALE
953 MALT LIQUOR
954 STOUT
955 PORTER
956 MALT BEVERAGES SPECIALITIES
957 CEREAL BEVERAGES - NEAR BEER (NON ALCOHOLIC)
959 OTHER MALT BEVERAGES

 

I can't speak to any other brewery's practices, but in the case of Changeling Dark Sour Ale, I can tell you that due to a change in the exempt ingredient list a few years ago that rolled barrel-aging into "traditional processes," breweries are no longer required to submit a formula for barrel-aging. When a formula was required, the TTB required you to state the type of barrels used as well as the blending percentage.

Since barrel-aging doesn't require a formula, we're not required to state the barrel types/blending percentages as prominently as we're required to state "malt beverage with natural flavors" on the can for Ginger Lemon Radler, but we still feel that mentioning the barrels/types is important so we chose to do so on the back label while leaving the front label more simple/artistic.

Does that help at all? I handle formula submission for BLVD so I'm comfortable answering any additional questions this might generate.