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Distilled Spirits Labeling: Color Ingredient Disclosures

 

Many distilled spirits contain color additives, which are generally added to impart color that is not natural to the product.  For certain class and/or types of distilled spirits, the standards of identity (SOI), 27 CFR 5.141-5.148, 5.150–5.152, 5.154-5.156 and 5.166, may permit the addition of coloring materials (such as caramel); otherwise, the addition of color would alter the class/type designation.  Coloring materials are not permissible in every class and/or type of distilled spirits. 

Coloring material information should be disclosed on a distilled spirits label in accordance with 27 CFR 5.63, and 5.72.  For information on the labeling of distilled spirits products that have been treated with wood please see 27 CFR 5.73.

Disclosure of Specific Coloring Materials - FD&C Yellow No. 5, Cochineal Extract, and Carmine

Three color additives must be specifically named on distilled spirits labels if present in the product: FD&C Yellow No. 5, cochineal extract, and carmine. For these products, the phrase "Contains [color additive name]" must appear on the product label.

Where should the color ingredient disclosure be placed on the product?

For FD&C Yellow No. 5

A distilled spirits product containing FD&C Yellow No. 5 is often required to bear a statement of composition on the label. In that case, the statement of composition may use the phrase "certified color" rather than specifically identifying FD&C Yellow No. 5, but FD&C Yellow No. 5 (or FD&C Yellow #5) must specifically be declared elsewhere on the product’s label.

For cochineal extract and carmine

A distilled spirits product containing either cochineal extract or carmineor both, is often required to bear a statement of composition on the label. In that case, the statement of composition may use the phrase "artificial color" rather than specifically identifying cochineal extract or carmine, but cochineal extract or carmine (or both) must specifically be declared elsewhere on the product’s label.

What are the formatting requirements for the color ingredient disclosure?

Type size

  • Minimum 2 mm for containers larger than 200 mL,
  • Minimum 1 mm for containers of 200 mL or less.
  • The minimum type size applies to each numeral or letter in the statement, including both upper-case and lower-case letters.

Legibility

  • Must be readily legible under ordinary conditions;
  • Must appear on a contrasting background; and
  • Must appear separate and apart from, or be substantially more conspicuous than, descriptive or explanatory information.

 

IMPORTANT

NOTE

See Distilled Spirits Labeling: Coloring Material Disclosures regulations at 27 CFR 5.63, 5.71, 5.72, and 5.73 (unless otherwise noted).

TTB G 2021-5

 

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Page last reviewed: June 30, 2021
Page last updated: December 21, 2022
Maintained by: Alcohol Labeling and Formulation Division

Last updated: April 5, 2024