Limited Ingredients

Flavoring Substances and Adjuvants Subject to Limitation or Restriction - TTB Limited Ingredients - Prohibited Ingredients - Coloring Materials

FDA – Center for Food Safety and Nutrition

Flavoring Substances and Adjuvants Subject to Limitation or Restriction (Please note: This table does not include materials used in the wine-making process that may have limitations. Please refer to 27 CFR Part 24.)

Acacia - Gum arabic 20%
Acetic acid 0.15%
Aconitic acid 0.002%
Adipic acid 0.02%
Agar 0.25%
Ammonium alginate 0.1%
Artemisia - Wormwood Finished product, thujone free
Bakers yeast extract 5%
Beeswax yellow & white 0.002%
Benzoic acid 0.1%
BHA - 0.02% edible fats & oils 0.5% of volatile essential oils
BHT (edible fats & oils) 0.02%
Bitter Almond oil Free from prussic acid
Brominated vegetable oil - BVO 15 ppm
Caffeine 200 ppm
Calcium acetate 0.001%
Calcium alginate 0.3%
Calcium chloride 0.05%
Calcium phosphate, dibasic 0.5%
Calcium phosphate, monobasic 0.02%
Calcium phosphate, tribasic 0.5%
Calcium pyrophosphate 0.2%
Calcium sulfate 0.07%
Camphor tree Safrole free
Caprylic acid 0.001%
Cedar, white (arborvitae)leaves & twigs Finished product, thujone free
Cherry pits 25 ppm prussic acid
Cherry - laurel leaves 25 ppm prussic acid
Cinchona, red & yellow bark 83 ppm total alkaloids
Corn silk & corn silk extract 4 ppm
Dithiols 1 ppm
EDTA 25 ppm
Elder tree leaves 25 ppm prussic in flavor
Ester gum (Glycerol ester of wood rosin) 100 ppm
Ethyl formate 0.01%
Guar gum 0.5%
Gum ghatti 0.1%
Gum tragacanth 0.1 %
Isopropyl citrate 0.02%
Karaya gum 0.002%
Licorice and licorice derivatives as Glycyrrhizin 0.1%
Locust bean gum 0.5%
Malic acid 0.7%
Mannitol 2.5%
Methylcellulose 0.003%
Methylparaben 0.1%
Mustard (allyl isothiocyanate) 0.02%
Mustard (brown/black/oriental) 1.0%
Mustard (yellow/white) 1.7%
Oak moss Finished product thujone free
Oak chips Labeling requirement
Oil of Rue 4 ppm
Peach leaves 25 ppm prussic acid
Potassium alginate 0.01%
Potassium metabisulfite 0.06%
Potassium sorbate 0.1%
Propylene glycol 5%
Propylparaben 0.1%
Quinine 83 ppm
Quinine bisulfate (as quinine) 83 ppm
Quinine hydrochloride (as quinine) 83 ppm
Quinine sulfate (as quinine) 83 ppm
Rue 2 ppm
Sassafras leaves Safrole free
Silicone 10 ppm
Sodium acid pyrophosphate 0.3%
Sodium alginate 1.0%
Sodium aluminosilicate 2.0%
Sodium benzoate 0.1%
Sodium calcium aluminosilicate hydrated 2.0%
Sodium carboxymethylcellulose 0.8%
Sodium hexametaphosphate 0.05%
Sodium phosphate, dibasic 0.5%
Sodium phosphate, monobasic 0.08%
Sodium phosphate, tribasic 0.07%
Sodium thiosulfate (alc. bev. only) 0.00005%
Sorbic acid 0.2%
Sorbitol 12%
St. Johnswort leaves, flowers & caulis Hypercin free
Stannous chloride 0.0015%
Stearyl citrate 0.15%
Sucrose acetate isobutyrate (SAIB) 300 ppm
Sulfur dioxide 10 ppm
Sulfuric acid 0.014%
Tagetes As oil only
Tannic acid 0.015%
Tansy Finished product, thujone free
Woodruff, sweet 5 ppm coumarin
Yarrow Finished product, thujone free

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TTB Limited Ingredients

There are 4 artificial flavor materials that TTB allows to be present at certain levels in alcoholic beverages without affecting the label declaration. If the levels of each of these, or a combination of them, exceed TTB's limitation the alcoholic beverage must be labeled as "imitation." The ingredients and their limits are: vanillin (40 ppm), ethyl vanillin (16 ppm), maltol (250 ppm), and ethyl maltol (100 ppm). Please note that these are individual limitations. When vanillin and ethyl vanillin (or maltol/ethyl maltol) are used in combination, the combined use calculated as vanillin may not exceed 40 ppm. In calculating the combined use, multiply the level of ethyl vanillin by 2.5 and add to the level of vanillin. This is the “total vanillin.” The same scenario applies to maltol and ethyl maltol.

Example:
a. Vanillin and ethyl vanillin are added by the distilled spirits producer in the production of a liqueur at a rate of 20 ppm of vanillin and 8 ppm of ethyl vanillin. The “total as vanillin” would be:

         20 + (2.5 X 8) = 40 ppm

In this example the producer would not have to label the product as imitation.

b. In another product, the producer adds maltol at the level of 125 ppm and ethyl maltol at 100 ppm. The “total as maltol” would be:

         125 + (2.5 X 100) = 375 ppm

In this example the “total as maltol” exceeds the maximum allowed of 250 ppm. Therefore the product would be labeled as imitation.

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Prohibited Ingredients

The Food and Drug Administration is responsible for determining which ingredients are prohibited from being used in food and/or beverage products. The laboratory enforces these restrictions for alcohol containing products. For more information go to: http://www.access.gpo.gov/nara/cfr/waisidx_00/21cfr189_00.html.

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Coloring Materials

Many alcohol beverage products contain coloring agents. Coloring agents are added to impart color which is not natural to the product. There are two categories of coloring agents that are used: FDA Certified Colors and Non-certified Colors. Certified colors are synthetic dyes approved by the FDA for use in beverage products. The non-certified colors are natural coloring agents approved for use in alcohol beverages. Below is a list of coloring agents which may be used in beverage products.

Certified Colors

**Must be specifically declared on the beverage label.

Non-Certified Colors

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