Alcohol FAQs

Rhamnus prinoides, also known as “Ethiopian hops” or “Gesho,” are not the same hops traditionally used in alcohol beverages that are addressed in the laws and regulations administered by TTB. The scientific name of the hop plant traditionally used and commonly understood to be used in alcohol beverages covered under the laws administered by TTB is Humulus lupus.

Consequently, “Ethiopian hops” cannot be used interchangeably with traditional hops when making alcohol beverages, including malt beverages.

FDA has not evaluated the safety of Rhamnus prinoides (“Ethiopian hops”) for use in alcohol beverages, has not issued a regulation authorizing the use of “Ethiopian hops” in alcohol beverages, and is not aware of a GRAS (Generally Recognized as Safe) conclusion for the use of “Ethiopian hops” in alcohol beverages.

Consequently, TTB will not approve an application for formula approval for an alcohol beverage that contains “Ethiopian hops.”

No. In TTB Ruling 2016-2, TTB approved general-use formulas for certain standard agricultural wines made from honey or certain other agricultural products. Under 27 CFR 24.203(a)(2), honey wine may be produced with hops in quantities not to exceed one pound for each 1,000 pounds of honey. However, this provision applies only to Humulus lupus, which are the hops traditionally used to make alcohol beverages, including malt beverages, addressed in the laws and regulations administered by TTB. See FAQ A30-A31 above.

The determination of whether a kombucha falls within the classification of a malt beverage, wine, or distilled spirits product under the FAA Act must be made on a case-by-case basis, depending on the formulation and method of production.  Products subject to the FAA Act must comply with its labeling and advertising regulations, trade practice rules, and additional qualification requirements.

Some alcohol beverages are subject to tax as beer, but are not subject to the requirements of the FAA Act. For example, beer (other than saké or similar products) that is made without both malted barley and hops is not subject to the labeling requirements of the FAA Act and must instead comply with FDA labeling requirements.  Such products are still subject to the marking requirements of the IRC and the health warning statement requirements of ABLA.

For more information on brewery products not subject to the FAA Act’s labeling and advertising regulations, see TTB Ruling 2008-3.

Last reviewed/updated: 09/17/2015

Yes. The inclusion of an optional alcohol content statement as part of a Serving Facts statement does not excuse industry members from compliance with existing regulations regarding the placement of mandatory alcohol content statements. The regulations require an alcohol content statement on the brand label for all distilled spirits and for those malt beverages containing alcohol derived from added flavors or other added nonbeverage ingredients (other than hops extract) containing alcohol. However, alcohol content statements may appear in more than one place on the container, provided that they are consistent and in compliance with all regulatory requirements. The percentage of alcohol by volume for wine containers may appear on any label.

If you are a producer, importer, or wholesaler of extraction products that are alcohol beverages (i.e. 0.5 percent or more ABV and fit for beverage purposes) you may be subject to the permit, labeling, and advertising requirements of the FAA Act, depending on the classification of the alcohol beverage product.* The determination of whether an extraction product, that is an alcohol beverage, falls within the classification of a wine, malt beverage, or distilled spirits product under the FAA Act must be made on a case-by-case basis, depending on the formulation and method of production.

Some alcohol beverages are subject to tax as wine or beer but are not subject to the requirements of the FAA Act. For example, wine containing less than 7 percent alcohol by volume, and beer that is not made with both malted barley and hops, are exempt from the labeling requirements under the FAA Act and must comply with FDA labeling requirements, as well as the marking requirements of the Internal Revenue Code of 1986 (IRC), as amended.

* For more information on the FAA Act, see 27 U.S.C. 201, et seq.

Honey wine is classified under the Internal Revenue Code of 1986, as amended (IRC), as an "agricultural wine." Agricultural wine is made from the fermentation of an agricultural product other than the juice of fruit. (See 27 CFR 24.200 and 24.203.) The production standards under 27 CFR part 24 for honey wine apply only to domestic products.

The IRC does not allow for the use of coloring or flavoring materials (other than hops) in standard honey wine. (See 26 U.S.C. 5387 and HW14 for more information.) Furthermore, wine spirits may not be added to standard honey wine, and standard honey wine may not contain more than 14 percent alcohol by volume. The IRC does provide for the production of wine specialty products that are made from a base of honey wine. These products are not standard agricultural wines, but are instead classified under the IRC regulations as "other than standard" (OTS) wines. (See 27 CFR 24.218.)

Under the regulations implementing the labeling provisions of the Federal Alcohol Administration Act (FAA Act), the standards of identity for wine made from the fermentation of agricultural products other than fruit are set forth in 27 CFR 4.21(f). Pursuant to these regulations, a product designated as "honey wine" must be derived wholly (except for sugar, water, or added alcohol) from honey. Wines designated as "honey wine" under 27 CFR part 4 also may contain hops, consistent with the levels set forth in part 24. TTB allows the designation "mead" to be used in lieu of "honey wine." (See HW6.)

Certain wines fermented from honey that do not meet the standards of identity under § 4.21(f) fall under the standards set forth in 27 CFR 4.21(h), and thus must be designated as "imitation" or "other than standard" (OTS) wines. Other specialty products do not fall under any of the standards of identity in part 4 and must be designated with a truthful and adequate statement of composition. (See 27 CFR 4.34(a).)

If you add coloring or flavoring materials (other than hops) to honey wine, the product is no longer a standard agricultural wine under the IRC. (See 26 U.S.C. 5387(b) and 27 CFR 24.200.) Furthermore, the product is no longer a "honey wine" under the FAA Act labeling regulations. However, you may produce a wine specialty product by adding flavoring and coloring materials to a base of honey wine. Because the product does not fall under any of the standards of identity set out in 27 CFR part 4, it must be designated with a truthful and adequate statement of composition, such as "honey wine with natural ginger flavor" or "mead with natural cherry flavor." The wine also may be labeled with a distinctive or fanciful name (such as "cherry honey delight"). In this case, TTB would not approve a label with a term such as "cherry mead" as either a fanciful name or a designation because it would be misleading as to the identity of the wine. However, a name such as "cherry-flavored mead" would be acceptable as the fanciful name, as long as an appropriate statement of composition appears as the designation.

TTB regulations at 27 CFR 24.203 state that the following may be added in the production of standard honey wine:

• Water to facilitate fermentation, provided the density of the honey and water mixture is not reduced below 13 degrees Brix;
• Hops in quantities not to exceed one pound for each 1,000 pounds of honey; and
• Pure, dry sugar or honey for sweetening. Sugar may be added only after fermentation is completed.

After complete fermentation or complete fermentation and sweetening, the wine may not have an alcohol content of more than 14 percent by volume or a total solids content that exceeds 35 degrees Brix.

All domestically produced agricultural wines, including honey wine, are subject to the formula requirements in 27 CFR 24.201. However, in TTB Ruling 2016-2 TTB approved general-use formulas for certain standard agricultural wines made from honey, dried fruit, or certain other agricultural products listed in the ruling and produced in accordance with the standards set forth in 27 CFR 24, subpart I. As a result, a person producing honey wine in accordance with 27 CFR §§ 24.200 and 24.203 is granted approval of a general-use formula and does not need to submit a formula to TTB. As provided in § 24.200, standard agricultural honey wine may not be colored or flavored (except that hops may be used as outlined in § 24.203), may not contain added spirits, and may not consist of wine made from one agricultural product that is blended with wine made from another agricultural product. Section 24.203 contains limitations on the use of sugar and water in the production of standard honey wine. Producers of honey wines that are not made in accordance with these regulatory standards must still submit a formula to TTB. Please see TTB Ruling 2016-2 for additional information.

If you wish to add coloring or flavoring materials (other than hops) to a honey wine base, or if you wish to blend honey wine with other wine, you must first obtain approval of a formula for an "other than standard" (OTS) wine under the IRC. (See 27 CFR 24.218.) (Also see HW10 and HW14 for information about the labeling of such products.)