Cideries

The cider industry has grown dramatically over the last few years. To date, the Alcohol and Tobacco Tax and Trade Bureau (“TTB”) has not created a cider-specific federal permit. It has, however, recently updated its policies and regulations pertaining to hard cider labels and excise taxes. 

In view of the frequent regulatory changes, and the absence of clear rules, labeling of hard cider can be one of the most challenging compliance tasks for cider producers. In fact, it is not uncommon for many manufacturers to wrongfully label their ciders, even if the products have been issued a TTB COLA.

Cideries: Services

Whether you’re starting your first cidery or are an established business seeking guidance, Lindsey Zahn P.C. is ready to provide meaningful, practical advice.  Among many other services, the firm can assist your cidery with the following:

• Determine the most appropriate federal TTB permit(s) for your business
• Draft and file the federal basic permit application with the TTB 
• Update and amend TTB permits
• Draft and file state license applications
• Update and amend state licenses
• Draft and submit formulas to the TTB for cider-based products that require formulation
• Review proposed labels for compliance with federal regulations
• Represent your cidery before the TTB during the COLA submission process
• Advise on developing a hard cider label under 7% alcohol by volume, subject to the regulations of the Food and Drug Administration (“FDA”);
• Provide ongoing legal compliance guidance

Recent Representations

Some recent representations include: 

• Advised on FDA regulations for a hard cider under 7% alcohol by volume
• Counseled a cider company on the use of non-apple and non-pear ingredients and implications on labeling and federal excise tax requirements
• Drafted the federal basic permit for a new cidery

For more information about how Lindsey Zahn P.C. can help your company, please contact us at lindsey@zahnlawpc.com.