TTB Issues Industry Circular on Hemp Ingredients

The Tax and Trade Bureau (TTB) has issued Industry Circular 2019-1, Hemp Ingredients in Alcohol Beverage Formulas, addressing the ability of industry members to produce alcohol beverages containing ingredients derived from hemp, such as cannabidiol (CBD). The circular explains current TTB policy on the use of hemp and discusses the critical role of the U.S. Food and Drug Administration (FDA) regarding these issues.

  • TTB will require a formula for any product containing a hemp-derived ingredient
  • TTB will not approve a formula for any product containing a Schedule I controlled substance under the Controlled Substances Act
  • TTB will not approve a formula for any product containing CBD until FDA changes its current position towards CBD as a food ingredient. FDA currently views interstate commerce in any food containing CBD as a violation of the federal Food, Drug & Cosmetic Act
  • TTB will continue to approve formulas for alcohol beverages containing ingredients derived from hemp seeds and hemp oil
  • TTB will not approve a formula for any product containing a hemp ingredient other than those derived from hemp seeds or oil unless it also receives adequate evidence that FDA deems the ingredient generally recognized as safe (GRAS) for food

Links

  1. Hemp Ingredients in Alcohol Beverage Formulas

Pete Johnson serves as the State & Regulatory Affairs Manager for the Brewers Association. He joined the BA at its inception in 2005, having previously worked as Programs Director for the Brewers Association of America. Before coming to the small brewing industry in 2001, Pete worked for 14 years with both state and federal elected officials in Pennsylvania and Washington, D.C.

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