AN INTERIM RULING FOR FISH EGGS

Last July the TTB issued a proposal that would require alcohol beverage companies to include common allergens, such as fish, on their labels. Anything that a consumer wouldn’t normally expect to find in wine, spirits or beer – such as fish, shellfish, milk, eggs, tree nuts, peanuts and soybeans – would fall under the labeling requirement.

The proposal has not yet been made a law, but in the meantime the TTB has published an interim rule that lays the woodwork for an optional allergen labeling statement. Basically, alcohol companies are not required at this time to declare any major food allergens in their products, but if they decide to do so they must follow these guidelines:

“An allergen declaration must consist of the word “Contains” followed by a colon and the name of the food source from which each major food allergen is derived. For example, a declaration could be ‘Contains: milk and egg.'”

If the allergen in question is a nut or Crustacean shellfish, for example, the specific type, (such as almond, pecan, crab or lobster) must be listed.

Winemakers that choose to list major food allergens on their wine labels must include all the major food allergens in the product, including fining or processing agents, unless TTB has approved a petition that voids that ingredient. Any person may petition TTB to exempt a particular product or class of products from the labeling requirements.

As far as the TTB is concerned, a food ingredient that is not considered a major allergen by the FDA does not need to be included on a warning label.