Co-Packing Resources:
Flavor Ingredient
Data Sheets (FIDS)
The TTB requires any flavors in alcoholic beverages to be registered and approved before they can be used. While flavor manufacturers keep their recipes confidential, the Flavor Ingredient Data Sheet lists certain ingredients that have usage rate limits set the TTB or which must be listed on your product label. FIDS are submitted in a standardized format and a TTB approved FIDS indicates that a flavor is allowable for use in alcoholic beverages.
FIDS sheets will list the supplier information and a TTB Drawback Number that must be included when your manufacturer files your product formula, along with the maximum usage rate allowed as a percentage of the beverage volume.
All natural or artificial flavors used in alcoholic beverages must have a TTB-approved FID Sheet. Your flavor suppliers will be very familiar with this requirement and should have no hesitation with providing the FIDS for your flavors.
It is possible that an allowable flavor has not yet been submitted to the TTB for beverage use. In that case, you can request that the supplier can submit an application with the TTB.
Formula approval processing times are listed and updated frequently at https://www.ttb.gov/formulation/fonl-processing-times
As a brand owner, you don’t need to particularly care about the contents of the FID Sheet. However, you should have a copy of the applicable FIDS and be able to provide those to your co-packing partner, because the co-packer must submit the FIDS allow with their application for approval of your formula.
An example FID Sheet can be found on the TTB website: https://www.ttb.gov/images/pdfs/sample-fid-sheet.pdf
Maximum Usage Rates
Per a 2005 Treasury Department decision, the TTB does not allow a beer or seltzer product to derive a significant portion of its alcohol from flavors or “other nonbeverage materials”. As many natural flavors use alcohol as the extraction and carrier medium, typically around 70-80% ABV, there is a potential impact to your flavor usage.
Your recipe formulation consultant should have already taken the maximum usage rates into account and should have only used pre-approved flavors. However, by downloading and using our seltzer formula calculator, you can determine for yourself how much additional alcohol your flavors and other ingredients are contributing.
Limits on alcohol in beer and malt beverages from non-fermented sources:
For products up to 6% ABV, not more than 49% of the total alcohol content
For products over 6% ABV, not more than 1.5% of the total beverage volume.
Source: TTB final rule TD-21
At The Nations, one of our first steps in any project is to conduct an internal evaluation of your formula and label. If we identify potential issues, then we will work with your and your formulation consultant to address and resolve those items, to ensure a smooth and quick approval process with the TTB. This article and any feedback during your project are guidance based on our experience with TTB formula and label approval, but they are not a substitute for advice from an attorney familiar with your state and Federal alcohol regulations.