Drawback Tutorial

• Drawback Tutorial Home
• TTB F 5154.1
• Glossary/References
  • Definitions
  • TTB actions
  • What is density?
  • What is specific gravity?
  • Important unit conversions
• Calculations
  • Calculation of eligible alcohol
  • Calculation of alcohol content of finished product
  • Calculation Worksheets
• Unfitness for Beverage Purposes
  • What makes a product unfit?
  • 1% solutions
  • Organoleptic Analysis
• Naming Nonbeverage Products
• Components of Formulas
  • Format of submissions
  • Common mistakes
  • Listing Ingredients in Your Formula
  • Identifying all sources of ethanol
  • Limited ingredients
  • Prohibited ingredients
  • Information about solid extracts
  • Artificial versus natural vanillin
  • Flavors purchased from other manufacturers
  • Compounded flavors manufactured in-house
  • Acids as flavoring chemicals
  • Botanicals allowed in flavors
• Submitting Samples with Formulas
• Revisions to Approved Formulas
• Special Products
  • Food products containing ethanol
  • Vanilla Extracts and Vanilla Flavors
• Example Formulas
  • Simple mixture 1
  • Simple mixture 2 (including discussion about yield)
  • Simple mixture 3 (includes a disapproved intermediate formula)
  • Simple extract
  • Washed extract (with multiple sources of ethanol)
  • Dietary Supplements 1
  • Dietary Supplement 2

Naming nonbeverage products

In general, products are named based on the U.S. Food and Drug Administration's (FDA) regulations.  Those guidelines are listed first.  If flavors are used in alcoholic beverages, TTB has more liberal guidelines for labeling of flavors used in alcoholic beverages.  Those are listed second.

FDA Guidelines

• Natural Flavors:  must contain a natural source of the named material and must be an all-natural product.  Any flavor materials present must be derived from the named ingredient.  For example, a natural strawberry flavor must contain a natural source of strawberry and all flavor materials must be derived from strawberry.
• Natural Flavors WONF:  must contain a natural source of the named material but may also contain other natural flavor materials.  These other natural flavors do not need to be derived from the named material.  For example, a natural strawberry flavor WONF must contain a natural source of strawberry but may also contain natural flavor chemicals not necessarily derived from strawberry (e.g. natural ethyl butyrate).
• Natural & Artificial Flavors:  must contain a natural source of the named material but may also contain artificial flavor materials.
• Natural Type Flavors, Natural Bases and Natural Keys:  natural flavors that do not contain the named ingredient.  For example, natural strawberry type flavor contains all natural ingredients but does not contain a natural source of strawberry.
• Natural & Artificial Type Flavors: contains both natural and artificial ingredients but does not contain a natural source of the named ingredient.
• Artificial Flavors:  predominant flavor is from artificial ingredients.

NOTE:  Any products containing artificial ingredients cannot have “WONF” in the name!

TTB Guidelines

• Natural & Artificial Flavors with 0.1% artificial topnote:  flavors containing not more than 0.1% artificial topnote are considered natural when used in alcoholic beverages.  The calculation of the amount of artificial material does not include artificial vanillin, ethyl vanillin, artificial maltol nor ethyl maltol. 
• When flavors are submitted for drawback of tax, the name should comply with FDA requirements (i.e. Natural & Artificial) even though TTB will consider them natural when they are used in alcoholic beverages.
• Natural & Artificial Flavors with greater than 0.1% artificial topnote:  considered for alcoholic beverage labeling purposes to be artificial.
• Other considerations:  TTB has limitations for artificial vanillin, ethyl maltol, artificial maltol and ethyl maltol in alcoholic beverages.  If these limitations are exceeded, the finished beverage will be considered an artificial product.
  
  Vanillin:  40 ppm
  Ethyl vanillin:  16 ppm
  Maltol:  250 ppm
  Ethyl maltol:  100 ppm
  
  ** Keep in mind that these limitations are in the finished alcoholic beverage; not in the flavor.  The actual amount present in the beverage will be calculated based on the use rate of the flavor.

• Wines containing < 7% by volume ethanol are subject to the FDA labeling guidelines listed above.