Formula Q&A with Michael Warren from the TTB
Last week we hosted a webinar with Michael from the TTB to talk about formulas. Here is a recap of some of the questions that were answered. If you have additional questions that you'd like to get answered in the future, you can put it in this post.
Here's a recap of some of the formula questions that were answered by the TTB
What is the number one reason for a formula being rejected?
The main reason a formula application is returned is due to a lack of detailed information. When in doubt, Michael suggests that you always provide as much information as possible.
When is a formula application needed?
The TTB has created a free tool that can give you guidance on whether or not you may need a formula approval, but there may be some exceptions. It's always best to reach out to the TTB if you're not sure.
A classic example of when a formula would not be needed is if you are a domestic vodka producer and you are not adding any citrus or sugar flavorings. If you are adding citrus or sugar flavors, you would need a formula approval. If you are changing any of the ingredients, a formula is needed, however if you are just changing a color additive, a new formula is not needed.
Is there any way to speed up the formula review process?
The formula review process can only be expedited if the producer can demonstrate some sort of hardship, otherwise it will be put in the normal queue. You are encouraged to contact the TTB to find out if your situation justifies an expedited formula review.
What is the difference between the "proof of distillation" and the "bottling proof"?
The proof of distillation is the highest point at which the spirit is taken off of the still and collected before it gets diluted. The bottling proof is the proof once it has been diluted.
Do I need a formula if I am using lactose as a sugar?
Lactose, like other natural sugars, is treated like normal sugar and does not need a special formula or require any special labeling requirement.
When will I need to provide a physical sample of my product with the formula?
A physical sample of the alcohol product is needed only if there are trace amounts of wormwood, or if the product is claiming to be non-alcoholic.
If my product contains organic ingredients, do I need to submit the organic certificate with the formula application?
If the product contains organic ingredients, the organic certificate does not need to be submitted with the formula, but it could be helpful to include.
Is the general public ever allowed to see a product's formulas?
No, formulas are kept secret by the TTB and are never released to the public.
Do I need a formula if I am adding essences to a product?
Whether or not you need a formula for essences depends on how the essences are being extracted, and if a preservative is involved. If a preservative is added, you will need a formula.
Do I need a formula if I am adding spices and seasonal fruits to beers?
With recent changes to TTB Ruling 2014-4 there are numerous fruits, spices, and other ingredients that are exempted from requiring a formula approval. You can see the full-list of exempted ingredients here.