Home.Scientific Services Division.Drawback Tutorial
Listing Ingredients in Your Formula
All ingredients used in flavors must be approved for food use by the U.S. Food and Drug Administration (FDA). The FDA lists these ingredients on their web site at:
Each ingredient in your formula does not need to be disclosed. TTB allows materials to be grouped together in nonbeverage formulas provided certain rules are met. The advantage of grouping materials together is that subtle changes can be made in the formula without resubmitting to TTB.
The following are examples of materials that may be grouped together:
In each category, predominant ingredients must be identified and quantified. Here is an example of a properly disclosed grouping of ingredients.
Total formula is 100 lbs
Benzaldehyde (FEMA # 2127, 1.23 lbs)
and other FEMA GRAS natural aldehydes …………………………………… 2.0 lbs
In this example, the class of flavor chemicals, natural aldehydes, is given along with the total weight of the group of ingredients. The predominant flavor chemical, benzaldehyde, is given along with its weight and FEMA number.
A sufficient quantity of ingredients in each category must be disclosed. TTB requires the following disclosure:
This allows TTB to make certain that the product will always be unfit for beverage purposes and provides investigators and auditors a method to determine compliance.
There are some restrictions in materials that can be grouped.
To properly group flavor chemicals, it is important to understand naming conventions:
Aldehydes: usually have aldehyde in the name or end with “al.” Examples include benzaldehyde, acetaldehyde, citral, and trans 2-hexenal.
Ketones: usually end with “one.” Examples include furanone, acetophenone, and ß-ionone.
Esters: usually end with “ate.” Examples include ethyl acetate, amyl butyrate, and cinnamyl formate.
Alcohols: usually end with “ol.” Examples include ethanol, citronellol, and geraniol.
(Note: do not group ethanol with other alcohols)
Some Important Tips: