|September 27, 2017||TTB G 2017-4|
TTB Public Guidance
Key FID Sheet Topics
If you're using a compounded flavor that was purchased from a flavor manufacturer, you should submit a FID sheet with your alcohol beverage formula. For this purpose, a compounded flavor includes any flavor, cloudifier, or blender that consists of multiple ingredients that are combined to produce a particular taste characteristic.
The FID sheet is filled out and signed by the flavor manufacturer. You may obtain a copy of the FID sheet from the flavor manufacturer(s) from whom you purchased the flavor(s) used in your alcohol beverage.
When you apply for formula approval of an alcohol beverage, you are required to provide information about the ingredients used in the production of the alcohol beverage. Flavor manufacturers do not typically provide detailed information about the composition of their flavors to alcohol beverage manufacturers, but you need to know what TTB and FDA limited ingredients are present in the flavors to ensure your beverages do not exceed allowable limits. The FID sheet is a way for the flavor manufacturer to provide the necessary information about limited ingredients.
TTB uses information about flavors used in your alcohol beverage to evaluate your product. Some ways that we use this information are:
- To ensure that the compounded flavor has been evaluated by the TTB Nonbeverage Products Laboratory (NPL) for compliance with U.S. Food and Drug Administration (FDA) requirements with regard to food additives,
- To verify that your beverage does not contain any ingredients in excess of the limits prescribed by TTB or by FDA for certain ingredients (for more information, visit our Limited Ingredients page and the Limited Ingredient Calculation Worksheet),
- To ensure the appropriate labeling of your product, and
- For malt beverages and beer, to make sure your beverage complies with our restrictions governing how much of the alcohol in your beverage may be derived from flavors and other nonbeverage ingredients containing alcohol (see 27 CFR 7.11 and 27 CFR 25.15 for information on these restrictions).
When looking at a FID sheet from a flavor manufacturer, you should make sure that it includes the following information:
- The name of the flavor
- The name, address, and contact information of the company that manufactured the flavor
- The TTB company code and the TTB drawback number, if available (Formulas Online will ask for these within the Formula tab, in the Ingredients section)
- The alcohol by volume of the flavor (which may be presented as a range)
- For domestic flavors, we strongly recommend that the FID sheet have a checked box indicating that the flavor has been Approved for Drawback (DrB) or Approved as No Action (N/A). If a flavor is imported, we strongly recommend that the FID sheet have a checked box indicating that the flavor has been Approved as No Action (N/A) or that it is Fit for Beverage Purposes (Fit). If the Submitted for TTB Approval box is checked, you may experience a delay in processing your beverage formula. If the Not Yet Submitted for TTB Approval box is checked, see the If the Compounded Flavor You are Using Has Not Been Submitted to TTB section below for more information.
- The classification of the flavor. Flavors can be classified as:
- Natural and artificial, with an artificial topnote less than or equal to 0.1% of the flavor
- Natural and artificial, with an artificial topnote greater than 0.1% of the flavor
- The total artificial flavor content
- Each limited ingredient that is used in the flavor, along with the parts per million
- All coloring additives and other ingredients that may affect the labeling of the product
- A signature from, and the title of, a representative of the flavor manufacturer
Make sure the FID sheet for your flavor contains the required information, and submit it in Formulas Online (after you enter your flavor information, or within the Docs/Links tab) or with TTB F 5100.51 as an attachment.
If the flavor manufacturer indicates that there are confidential limited ingredients present in the flavor as it was submitted to TTB, the FID sheet should reflect that.
(See the Confidential Limited Ingredient section in our FID Sheet: Example .) The flavor manufacturer should check a box indicating if the confidential limited ingredient is contained in the nonbeverage formula, or if it was previously submitted to TTB. This allows the manufacturer to refer TTB to the flavor manufacturer's nonbeverage formula submission without revealing the confidential limited ingredients to you.
Ask the flavor company to submit a nonbeverage formula application to TTB using Formulas Online or TTB Form 5154.1. Once the flavor formula has been submitted to TTB, ask the flavor company to provide you with an updated FID sheet, which reflects submission to TTB. You may then submit your beverage formula and the properly updated FID sheet.
Keep in mind that flavor information is confidential, and thus the Nonbeverage Products Laboratory may not disclose such information to you. If you need this information, you may contact the flavor manufacturer directly.
This information may be submitted in any format, as long as the necessary information is included. Here are links to the preferred FID sheet format and an example FID sheet:
Once the required information is entered in the TTB sample spreadsheet, it will automatically calculate the maximum usage rate of a flavor that contains ingredients that are subject to TTB or FDA limitations.