Use of the Word ‘Clean’ in Alcohol Beverage Labeling and Advertising
Posted 4/8/2022 by the Market Compliance Office
We’ve received inquiries about the meaning of the word “clean” when used in the labeling and advertising of alcohol beverages subject to the Federal Alcohol Administration Act. TTB regulations do not define the word “clean,” and we do not have standards for the use of the term on labels or in advertisements. Thus, consumers should not interpret the term as meaning that the beverage is organic or has met other production standards set by TTB. Instead, we review both labels and advertisements in their totality to determine if they create a misleading impression.
In some cases, the term “clean” is simply being used as a descriptor of the taste of the beverage, and is considered puffery. For example, “X winery makes a clean, crisp wine.”
In other cases, the term is used together with other language to create the misleading impression that consumption of the alcohol beverage will have health benefits, or that the health risks otherwise associated with alcohol consumption will be mitigated. For example, ”X malt beverage is clean and healthy” or “Y vodka’s clean production methods mean no headaches for you.”
We would consider those claims to be misleading health-related statements.