Industry Circular

Number: 77-16

Date: August 2, 1977

Department of the Treasury

Bureau of Alcohol, Tobacco and Firearms

Washington, DC 20226

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VANILLA SAMPLING PROGRAM

Manufacturers of Nonbeverage Products and Others Concerned

Purpose. This circular is issued to advise manufacturers of nonbeverage products that the Bureau of Alcohol, Tobacco and Firearms is conducting an intensified sampling program on vanilla extracts and flavors.

Background. The Bureau has found that in an increasing number of instances synthetic vanillin has been substituted for natural vanilla beans in the production of vanilla extracts. Similarly, in the case of vanilla flavors, the Bureau has found that synthetic vanillin has been used in quantities exceeding that specified on approved formulas on ATF Form 1678, Formula and Process for Nonbeverage Product. In instances of this type, the product manufactured has not been produced according to approved formulas.

Compliance. During inspections of drawback claims, inspectors will be taking samples of vanilla extracts and flavors of various strengths, batches and formulations. The samples will be analyzed by ATF chemists to verify production according to approved formula. Where it is found that alcohol has been used in products which have not been manufactured in strict accordance with approved formulas, drawback of tax will not be allowed on the alcohol so used.

Inquiries. Inquiries concerning this circular should refer to its number and be addressed to the office of your regional regulatory administrator.

Rex D. Davis Director