From expression names and type of booze to ABV, production location, batch number, and more, there’s a lot of language on alcohol labels. And unless you know the ins and outs of every single labeling requirement of the Alcohol and Tobacco Tax and Trade Bureau (TTB), some of this language can be puzzling or even misleading.
Unlike other food and drink products, alcohol products are not required by law to have each and every ingredient listed on the label. While this certainly does not mean producers can add whatever they want to their beverages (there are long lists of both prohibited and limited ingredients), the lack of ingredient labeling and use of broad language can result in confusion regarding what exactly is in a bottle. But we’re here to break it down for you.
From tequila versus 100 percent Blue Weber agave to “natural flavors,” here are what labels on alcoholic beverages actually mean, according to the TTB.
The Mexican government has owned the rights to the term “tequila” since it was declared an official Denomination of Origin (DO) in 1974. Through the Consejo Regulador del Tequila (CRT), a non-governmental organization funded by the Mexican government, use of the term is regulated to ensure that all products are in compliance with the Norma Oficial Mexicana (NOM), or the Official Mexican Standard. According to the CRT, in order for a spirit to be labeled tequila, it must be produced in one of the areas authorized by the DO: Jalisco or specific municipalities in Guanajuato, Michoacán, Nayarit, and Tamaulipas. Additionally, the DO states that all tequila must be made from Blue Weber agave and bottled between 35 and 55 percent ABV. If made outside these regions or production methods, a spirit cannot legally be called tequila.
But while all tequila must be made from Blue Weber agave, 100 percent of the spirit is not required to be distilled from the plant. Instead, the CRT only mandates that 51 percent be distilled from Blue Weber agave sugars. The remaining 49 percent can be composed of other fermentable sugars, artificial colors, or additives. Commonly referred to as “mixto,” these spirits can be bottled both inside and outside territories defined by the DO, with most labels reading “Made with Agave” rather than displaying the percentage of Blue Weber used. Conversely, labels reading “100% Blue Weber Agave,” “100% de Agave,” or “Tequila 100% Agave,” are certified to be entirely produced from Blue Weber agave. These tequilas must be bottled at origin and are known for their purer, more authentic production styles and flavors.
The TTB requires that all products sold in the United States labeled “tequila” are “manufactured in Mexico in compliance with the laws of Mexico regulating the manufacture of Tequila for consumption in that country.”
Similarly to tequila, bourbon is also a protected spirit and has been since the U.S. Congress declared the whiskey a “distinctive product of the United States” in 1964. But while all bourbon must be made in the U.S., different classifications of bourbon can mean different things. As outlined by the TTB, in order to be labeled “bourbon,” the whiskey must be produced in the U.S. from a fermented mash of at least 51 percent corn. The mash itself cannot be distilled over 160 proof (80 percent ABV) and the bourbon must be barreled at no higher than 125 proof (62.5 percent ABV). When bottled, the bourbon must be bottled at a minimum of 40 percent ABV.
Building on these production regulations, straight bourbon must meet all of the criteria for bourbon, but must age for at least two years in new, charred oak barrels. If the spirit was aged for less than four years, the label must also include an age statement of the youngest bourbon in the bottle. Restrictions around additives are also stricter. According to the TTB, spirits labeled “Straight Bourbon Whiskey” may include mixtures of two or more straight bourbons, provided each was was produced in the same state.
“Natural flavors” are one of the most frequently cited ingredients on canned cocktail and hard seltzer labels, and yet they are one of the most vague. According to the TTB, natural flavors are flavors derived from a natural source such as spices, fruits, vegetables, plants, meat, or dairy products. In order for a product to say it contains natural flavors, it must “contain a natural source of the named material and must be an all-natural product” and “any flavor materials present must be derived from the named ingredient.” For example, if a product is labeled as containing “natural lime,” it must contain a natural source of lime and all flavor present must come from lime.
“With Other Natural Flavors” on a label indicates that a product contains a natural source of the named material, but can also contain natural flavor chemicals not necessarily derived from that material. So if a product reads “natural lime with other natural flavors” or any variation thereof, the various other flavoring agents do not need to be derived from lime and can instead come from other natural flavoring chemicals.
While flavors must be derived from a natural source in order to be labeled as such, the TTB does permit flavoring agents to contain up to 0.1 percent artificial top notes. (This limitation does not apply to ethyl vanillin, vanillin, ethyl maltol, and maltol, which are all permitted in quantities up to 16 parts per million, 40 ppm, 100 ppm, and 250 ppm.) If this limit is exceeded, producers must label their products as having artificial flavoring.
While natural flavors refer to flavors derived, at least in part, from the natural named ingredient, artificial flavors (a.k.a. artificial flavoring) refers to any ingredient intended to impart flavor that is not derived from the aforementioned spices, fruits, vegetables, etc. However, simply because artificial ingredients are permitted in some alcohol production, does not mean producers are able to add as many as they desire. The TTB mandates that artificial flavoring agents “can only be used in the minimum quantity required to produce their intended effect” and are used “in accordance with the principles of good manufacturing practices.” There are hundreds of approved synthetic flavor substances and adjuvants and if any are used, manufacturers are required to include a statement of artificial flavoring, artificial coloring, or chemical preservatives on labeling.
While other ingredients on this list are more closely controlled, there isn’t much regulation regarding the use of terms such as “real juice,” and “made with real fruit.” If a product purports to be made from real fruit or contain real juice, the statements can be assumed true (they have to be in order for brands to receive label approval), but there is no specific percentage of real fruit required by the TTB in order for an alcoholic beverage to be labeled as containing “real fruit.” It has to be present, but it can be as little as 1 percent real fruit making its way into the final product. The remainder can be composed of other fruit juices, natural ingredients, or artificial flavors. On the flip side, if a label reads “100 percent fruit juice,” the claim has been investigated and approved by the TTB that real juice is used during production.
*Image retrieved from Mariya via stock.adobe.com
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