In January both the Alcohol and Tobacco Tax and Trade Bureau (TTB) and the Food & Drug Administration (FDA) published proposals for new labeling regulations that would substantially impact America’s small and independent brewers, as well as other producers and importers of alcohol beverages. We now seek input from members in order to best protect the interests of small and independent brewers.

In keeping with normal practice in rulemaking proceedings, the Brewers Association (BA) plans to submit its written comments to the TTB near the deadline for filing comments. In the case of the two TTB rulemakings on “alcohol facts” and mandatory allergen labeling, comments are due on or before April 17, 2025. In the case of the FDA’s front-of-label requirement, which would apply to products like fermented hard seltzers and most hard ciders, the comment deadline is May 16, 2025. Interested parties can request an extension of any comment period, but there is no guarantee that an agency will grant such requests.

Filing comments is important, as agencies like the TTB and FDA review them and may adjust the final regulations based on input received during the comment process. Whether the comments seek a change from what an agency proposed or support the proposal, comments give interested parties a chance to have their say.

To assist us in preparing and filing comments on these rulemaking proposals, the BA has prepared a survey for members to gather key information that will better inform our comments and the agencies in question. We ask members to fill out this survey on or before April 10, 2025 so that we can best protect craft brewer interests through the comment process.

The BA’s summary of those proposals, as well as our comments during the process leading up to the TTB’s rulemaking notices, can be found at the links below.

• TTB Proposes Sweeping New Regulations Mandating Alcohol Content, Allergen, and Nutritional Information on Labels
• FDA Proposes Front-of-Packaging Labeling Mandate for Most Packaged Foods
• Brewers Association Submits Comments to TTB on Mandatory Labeling Issues