In 2013, the Alcohol and Tobacco Tax and Trade Bureau (“TTB“) published TTB Ruling 2013-2 which discusses the use of a statement of average analysis and a Serving Facts statement on alcohol beverages. The statements are a standardized format used to provide consumers with essential information on alcohol beverage servings on the product’s label. Although generally voluntary for most products, it has become increasingly relevant for manufacturers who wish to offer transparency regarding nutritional information, alcohol content, and caloric values.
What is the TTB Serving Facts Panel?
The TTB Serving Facts panel provides details about the nutritional content of an alcohol beverage. Though it is generally not required, many producers voluntarily include this panel to give consumers a clearer understanding of the product’s contents. The panel typically includes information about calorie count, carbohydrates, protein, and fat per serving, along with serving size. (In some instances, such as when a label makes claims about calorie count, carbohydrates, or similar, the statement may be be required.)
When is the TTB Serving Facts Panel Required?
While the TTB does not mandate the Serving Facts panel for most alcohol beverages, if the brand or product name, or any part of the advertising, includes terms like “low carb” or “low calorie,” or specific calorie or carbohydrate content claims, then TTB’s serving facts ruling will apply. This regulatory approach aims to balance transparency and accurate consumer information while limiting misleading claims.
What Must Appear on the Serving Facts Panel?
The TTB provides detailed guidance on the information to be displayed on the Serving Facts panel:
- Serving Size: Standardized by beverage type, with wine typically using a 5-ounce serving size, beer at 12 ounces, and spirits at 1.5 ounces. A Servings Per Container statement is also required based on the serving size.
- Calories: The total caloric content per serving, calculated based on alcohol and other macronutrient content.
- Fat: Listed as “0g” if absent or under 0.5g per serving.
- Carbohydrates: Carbohydrates are displayed in grams per serving.
- Protein: Similarly listed in grams, typically as “0g” unless otherwise applicable.
Format Requirements
The TTB mandates that the Serving Facts panel follow a structured format similar to FDA nutritional labels:
- Font and Style: All information must be presented in a legible, uniform font with specific emphasis on readability.
- Placement: Typically included on the back or side of the product packaging.
- Layout: Information should be neatly aligned, with clear headings for each nutritional category.
Failure to meet these format requirements can lead to label rejection by the TTB during the application process.
Benefits of Including the Serving Facts Panel
While optional, the Serving Facts panel offers significant advantages to brands in the craft and premium segments who wish to align with consumer demands for transparency. A clear display of calorie and carb counts can attract health-conscious consumers and foster trust.
Compliance and Voluntary Use
Although generally optional, any voluntary Serving Facts panels must fully comply with TTB standards, ensuring accuracy and preventing misleading claims. The TTB recommends that producers consult a regulatory expert to ensure compliance, as labeling errors can delay product approval and lead to costly modifications.
How Can Lindsey Zahn P.C. Assist With Your Alcohol Beverage Labels?
The Serving Facts panel is a powerful tool for educating consumers while meeting evolving demands for transparency. Even though it is not required for all products, including it voluntarily can be a strategic choice for mead, wine, and craft beverage producers. For more information on implementing this panel, reach out to Lindsey Zahn P.C. for guidance on TTB compliance, label requirements, and application support.
Reach out to Lindsey Zahn P.C. for an introductory meeting to discuss your project at 929-ZAHNLAW or info@zahnlawpc.com.