Sulfites and Aspartame
Aside from color additives, two additives must be specifically named on product labels when present in a malt beverage:
- Sulfites
- Aspartame
What are sulfites and where should the sulfite declaration be placed on the product?
For purposes of this guidance, the term “sulfites” includes sulfur dioxide and sulfiting agents. Sulfites are preservatives used in the production of malt beverages, and some people have sensitivities to sulfites. The labeling requirement is intended to alert those people to the presence of sulfites in the malt beverage product.
A sulfite declaration is a statement on labels of malt beverages that informs the consumer that the product contains sulfites or sulfiting agents. The statement is required where sulfur dioxide or a sulfiting agent is detected at a level of 10 or more parts per million (ppm), measured as total sulfur dioxide. See 27 CFR 7.63(b)(3).
Sulfite Declaration
- A sulfite declaration is mandatory for malt beverage containing 10 or more parts per million (ppm) sulfur dioxide. Such declarations are optional if the product contains less than 10 ppm sulfur dioxide. It may appear on any label, including a strip label or neck label.
EXAMPLES: “Contains sulfites” or “Contains (a) sulfiting agent(s)”
In this example, the sulfite declaration appears on the back label of the product.
NOTE:
- “Sulphites” may be used in lieu of “sulfites” in mandatory and optional sulfite declarations.
- TTB does not permit statements such as “sulfite free,” “free of sulfites,” or “contains no sulfites.”
What is aspartame and where should the aspartame declaration be placed on the product?
The U.S. Food and Drug Administration regulations state that aspartame is a food additive that may be safely used in food in accordance with good manufacturing practice as a sweetening agent and a flavor enhancer under certain conditions (see 21 CFR 172.804).
An aspartame declaration must appear on a malt beverage that contains aspartame. This labeling requirement is intended to alert consumers to the presence of aspartame in the malt beverage product. See 27 CFR 7.63(b)(4).
Aspartame Declaration
- Must appear on the product’s label, but may appear on any label.
- Must appear in capital letters, separate and apart from all other information.
Required declaration: “PHENYLKETONURICS: CONTAINS PHENYLALANINE.”
In this example, the aspartame declaration appears on the back label of the product.
What are formatting requirements for these declarations on the label?
Type size:
- Minimum 1 mm for containers of 1/2 pint or less
- Minimum 2 mm for containers larger than 1/2 pint
Note: The minimum type size applies to each numeral or letter in the statement, including both uppercase and, in the case of sulfite declarations, lowercase letters. See 27 CFR 7.53 and 7.63(b)(3)-(4).
Legibility:
- Must be readily legible under ordinary conditions;
- Must appear on a contrasting background;
- Aspartame declarations must appear separate and apart from all other information; and
- Sulfite declarations must appear separate and apart from, or be substantially more conspicuous than, descriptive or explanatory information.
More information on these requirements is available at 27 CFR 7.52 – 7.53 and 7.63(b)(3)-(4).
Is formula approval required for products containing sulfites or aspartame?
Malt beverages that contain sulfites, aspartame, or other additives require formula approval prior to applying for label approval. See 27 CFR 25.55 and TTB G 2016-1A.
Page last reviewed: April 11, 2023
Page last updated: April 11, 2023
Maintained by: Alcohol Labeling and Formulation Division