Procedures 2020-1

September 28, 2020
Number: 2020-1

Subject: Testing of calorie, fat, carbohydrate, and protein content of alcohol beverages; Acceptable tolerance levels

I. Purpose.

The purpose of this procedure is to notify you of the methods TTB uses to test calorie, fat, carbohydrate, and protein content of alcohol beverages to verify labeling and advertising claims. This procedure also addresses tolerance ranges with regard to statements of calorie, fat, carbohydrate, and protein content.

II. Background.

As specified in TTB Ruling 2004-1 and TTB Ruling 2013-2, if you wish to make caloric and/or carbohydrate representations in the labeling or advertising of wine, distilled spirits, or malt beverages, you must also include, with that information, a statement of average analysis or a Serving Facts statement, as set forth in those rulings. 

III. Expression of Calorie, Fat, Carbohydrate, and Protein Content.

For labeling and advertising purposes, calories, fat, carbohydrates, and protein must be expressed as specified below:

A. “Calories:” -- A statement of the caloric content per serving must be expressed to the nearest calorie except that amounts less than 5 calories may be expressed as zero. 

B. “Fat” -- A statement of the number of grams of total fat in a serving (with total fat defined as total lipid fatty acids and expressed as triglycerides) must be expressed to the nearest 0.5 (1/2) gram increment below 5 grams and to the nearest gram increment above 5 grams. If the serving contains less than 0.5 gram, the content may be expressed as zero.

C. “Carbohydrate” -- A statement of the number of grams of total carbohydrates in a serving must be expressed to the nearest tenth of a gram, except that if a serving contains less than 1 gram, the statement “Contains less than 1 gram” or “less than 1 gram” may be used as an alternative, or if the serving contains less than 0.5 gram, the content may be expressed as zero.

D. “Protein” -- A statement of the number of grams of protein in a serving must be expressed to the nearest tenth of a gram, except that if a serving contains less than 1 gram, the statement “Contains less than 1 gram” or “less than 1 gram” may be used as an alternative, and if the serving contains less than 0.5 gram, the content may be expressed as zero.

Industry members may round the number of calories, or the number of grams of carbohydrates, protein, and fat, in a serving of the product, as long as the labeled or advertised content falls within the tolerances set forth in this Procedure.  Thus, for example, regardless of whether the calories per serving for a particular product are expressed as 98 or 100, the labeled or advertised calorie statement must be within the prescribed tolerance for the value that is expressed.

IV. Methods Used to Validate Calorie, Fat, Carbohydrate, and Protein Content Statements.

TTB periodically reviews labeling and advertising claims by taking samples of alcohol beverage products for validation purposes. To validate these claims, we use the TTB methods referenced below, which are applicable to all alcohol beverages and based on AOAC methods. These methods of analysis meet the definitions referenced in Section III of this procedure. We consider your advertising and labeling claims acceptable if, when we evaluate your product using these methods, we find that they fall within the tolerance levels specified in Section V of this procedure. 

* Access to AOAC methods is available from AOAC INTERNATIONAL.

V. Tolerances.

TTB has determined that tolerance ranges are required with respect to labeled and advertised statements of caloric, fat, carbohydrate, and protein content for alcohol beverages. The intent of these tolerances is to provide for normal production and analytical variables while continuing to ensure that the labeling does not mislead the consumer. The tolerance levels are specified below:

A. Caloric Content: The statement of caloric content on labels or in advertisements for alcohol beverages will be considered acceptable as long as the caloric content, as determined by TTB analysis, is within a reasonable range below the labeled or advertised amount (within good manufacturing practice limitations) but may not be more than 20 percent above the labeled or advertised amount. For example, a label or advertisement showing 100 calories per serving will be acceptable if TTB analysis of the product shows a calorie content of not more than 120 calories per serving.

B. Carbohydrate and Fat Content: The statements of carbohydrate and fat content on labels or in advertisements for alcohol beverages will be considered acceptable as long as the carbohydrate content and the fat content, as determined by TTB analysis, are each within a reasonable range below the labeled or advertised amount (within good manufacturing practice limitations) but may not be more than 20 percent above the labeled or advertised amount. For example, a label or advertisement showing 4.0 grams of carbohydrates per serving will be acceptable if TTB analysis of the product shows a carbohydrate content of not more than 4.8 grams per serving.

C. Protein Content: The statement of protein content on labels or in advertisements for alcohol beverages will be considered acceptable as long as the protein content, as determined by TTB analysis, is within a reasonable range above the labeled or advertised amount (within good manufacturing practice limitations) but may not be more than 20 percent below the labeled or advertised amount. For example, a label showing 1.0 gram protein per serving will be acceptable if TTB analysis of the product shows a protein content of not less than 0.8 gram per serving.

VI. Questions and Inquiries.

If you have any questions regarding this Procedure please contact the Compliance Laboratory at (513) 684-3356 or use the Scientific Services Division contact form.

Date signed: September 28, 2020

Mary G. Ryan
Administrator
Alcohol and Tobacco Tax and Trade Bureau

Page last reviewed: September 28, 2020
Page last updated: September 28, 2020
Maintained by: Scientific Services Division