This article was originally published on December 6, 2024. It was most recently updated on December 19, 2024.
On Thursday, December 5, the Alcohol and Tobacco Tax and Trade Bureau (TTB) issued Industry Circular 2024-2, exempting 24 brewing ingredients from the agency’s formula submission and approval requirements. The Industry Circular responds to two petitions filed by the Brewers Association (BA)—one in 2021 and one in 2023—requesting further exemptions from formula requirements. The TTB has previously exempted over 50 brewing ingredients from formula requirements in response to earlier petitions by the BA.
With the new Industry Circular, the TTB has added the following ingredients to its formula exemptions:
- Almonds
- Bananas*
- Beets*
- Cantaloupe*
- Carrots*
- Cucumbers*
- Dandelion Leaves/Greens*
- Dill*
- Dragon Fruit*
- Elderberries*
- Guava*
- Hazelnuts
- Lavender [includes lavender and spike lavender; whole, juice, puree, or concentrate]
- Lychee Fruit*
- Papaya*
- Peanuts
- Pecans
- Pistachios
- Prickly Pear Fruit*
- Rhubarb [includes stalks or stems; whole, juice, puree, or concentrate]
- Rose Hip*
- Spruce [only the tips, needles, and twigs of the species Picea glauca (Moench) Vossor P. mariana (Mill.) BSP]
- Tea [only varieties of leaves of Camellia sinensis, whether whole or ground. Includes Earl Grey tea when the only additional ingredient(s) are dried bergamot orange peel and/or bergamot extract or oil. Exemption does not cover products made solely from fermented tea and sugar (i.e., kombucha)]
- Walnuts
*Includes whole, juice, puree, or concentrate.
Brewers should recognize that the exemption of a particular ingredient such as a fruit or nut does not exempt the use of an extract, essential oils, or syrup (i.e., a flavoring) made of that ingredient from formula requirements. Going forward, using the ingredients above will not trigger the need to submit and receive TTB approval of a formula for the beer product in question.
The BA applauds the TTB’s continued commitment to common sense regulatory streamlining measures and looks forward to working with the agency in the future to further reduce regulatory burdens on the industry and government resources.