Envelope Get Email Updates

Back to Nonbeverage Products Laboratory page

Drawback Tutorial

Common Mistakes

  1. Mixed units, no units, or improper units for quantities of ingredients – Frequently, TTB receives formulas that use percentages for the ingredient quantities or several different units of measure (mixed metric and English units, mixed English units, etc.).  While these problems do not always necessitate returning the formula to the submitter, dealing with the conversions often adds a significant amount of time to processing the formula.  Because of potential ambiguity, please do not use percentages when expressing quantities.
  2. No yield or very little yield information –Please express  the yield in both mass and volume units.  Volume is particularly important because the tax and drawback are calculated based on it. 
  3. Improper grouping of flavor chemicals – Do not include natural and artificial flavor chemicals in the same group.  Additionally, separate flavor classes (see section on classes of ingredients for more information).  Please note that some acids are not considered flavor chemicals (see the section on acids).  When grouping materials, be sure that the group does not contain TTB or FDA limited ingredients.  Those must be listed as separate items.
  4. Failure to disclose solvents, colors, and limited ingredients in purchased compounded flavors, solid extracts essences and other products. Include a specification sheet to substantiate the presence or absence of limited ingredients whenever possible (see documentation guidelines).  If a specification sheet is not available, include a note on each copy of the formula indicating that the manufacturer has declared the presence or absence of limited ingredients or colors.
  5. Use of obscure names or shorthand to identify ingredients – Trade names and shorthand may or may not be recognizable to TTB.  Please try to use the chemical name or provide vendor information that will help identify the ingredient.  If you do not have the chemical name, please include a FEMA number.
  6. Failure to provide TTB number for purchased flavors – If a purchased or self-manufactured compounded flavor contains ethanol (≥0.5% by volume), it should have a TTB number.  Some exceptions to this are essences, distillates, and some simple extracts.  This information should be available to you on the FIDS provided by the vendor.  It is your responsibility to provide this information to TTB.
  7. Making blanket statements such as “all ingredients FEMA GRAS” instead of listing the ingredients in box 13 - You must provide a quantitative list of ingredients to obtain approval.
  8. Failure to provide an unfitness for beverage statement – Please cite a specific guideline. If the product contains less than 0.5% alcohol by volume (<0.5% ABV), then write “non-alcoholic” as the unfitness statement.​
Page last reviewed/updated: 06/10/2021