On May 28, 2013, the Alcohol and Tobacco Tax and Trade Bureau (TTB) published a new Industry Circular, Number 2013-2, that authorizes voluntary “serving facts” labeling on alcohol beverages regulated by TTB under the Federal Alcohol Administration Act (i.e., it does not apply to wine below 7 percent alcohol by volume (ABV) or beers made without malted barley or hops).
The most relevant points:
- Everything discussed in Industry Circular 2013-2 concerns voluntary labeling statements. It mandates no new labeling disclosures.
- The serving facts statement mostly contains the same information contained in the “statement of average analysis” required for “light” and similar products.
- TTB gives producers and importers the option of adding a statement showing the amount of pure alcohol per serving or per container of a product (e.g., 0.6 fl. oz. of alcohol per serving), accompanied by alcohol content (ABV) information.
- The serving facts can be displayed in a panel (FDA style) or “linear” fashion.
- Producers and importers have the option of showing serving facts as a substitute for the statement of average analysis required on “light” and similar products.
- TTB recognizes a wider range of serving sizes for wine, malt beverages and distilled spirits, depending on the strength of the product. For example, instead of a 12 oz. serving size for all malt beverages, serving facts statements for higher-strength beers should use smaller serving sizes for progressively higher-alcohol products.
- If a producer or importer follows the format authorized by TTB, it can add serving facts to existing labels without the need for a new COLA.