Kombucha Labeling Requirements
Click on the questions below to reveal answers explaining kombucha labeling requirements. (Go back to main Kombucha page.)
Yes, if the kombucha beverage contains 0.5 percent or more alcohol by volume. The container of any alcohol beverage sold or distributed in the United States with an alcohol content of 0.5 percent or more must bear the health warning statement required by the Alcoholic Beverage Labeling Act of 1988. (See 27 U.S.C. 215 and 27 CFR part 16.) This requirement applies regardless of whether the kombucha is subject to the labeling requirements of the Federal Alcohol Administration Act (FAA Act). (See K13.)
See 27 CFR part 16 for the wording, type size and other formatting rules regarding the health warning statement.
Last reviewed/updated: 09/17/2015
IRC labeling requirements apply to all kombucha products that contain 0.5 percent or more alcohol by volume, regardless of whether the product is also subject to the labeling requirements of the FAA Act. (See K13.)
If your kombucha is classified as a beer, you must comply with the labeling and marking regulations at 27 CFR 25.141-25.145, including the requirement that each container must show by label or otherwise:
- The name or trade name of the brewer;
- The net contents of the container;
- The nature of the product (such as “beer”); and
- The place of production.
Last reviewed/updated: 09/17/2015
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
IMPORTANT
TTB regulations on alcohol beverages DO APPLY to any kombucha that has less than 0.5 percent alcohol by volume when bottled BUT the alcohol content increases to 0.5 percent or more alcohol by volume at any point afterwards as a result of continued fermentation in the bottle.
Failure to comply with federal laws and regulations governing the production, bottling, labeling, and distribution of alcohol beverages, including kombucha that contains 0.5 percent or more alcohol by volume, may lead to enforcement actions, such as the assessment of tax, penalties, and interest, in addition to potential civil and criminal penalties.
CONTACT US
Questions? Please contact the Alcohol Labeling and Formulation Division at 202-453-2250 or Toll Free 866-927-ALFD (2533), or by email at Submit an Online Inquiry .