On August 15 the Brewers Association (BA) filed comments on two important Alcohol and Tobacco Tax and Trade Bureau (TTB) rule making projects. TTB Notice 237 would impose “alcohol facts” nutritional labeling on most beer that moves in interstate commerce (i.e., crosses state lines). Notice 238 would impose mandatory allergen disclosures on beer containing any of the “big nine” allergens that moves in interstate commerce.

The Brewers Association’s (BA) comments on nutritional labeling stress the potential impact of any final rules on small and independent brewers. The BA applauded the proposed rules’ greater tolerances for nutritional and alcohol content statements, as well as its proposed five-year implementation period after any regulations become final. Nevertheless, the BA stressed that a final rule will impose burdens on struggling craft brewers. Among other things, the BA’s comments renew its call for TTB to adopt a different rule or exemption for small batch products or the products of small businesses.

The Brewers Association’s (BA) comments on allergen labeling reaffirm the association’s longstanding support for label disclosure of the presence of any of the major food allergens as established by Congress. The BA’s comments, however, advocate for a number of changes to the proposed regulations that would reduce the burden of mandatory allergen labeling on the craft beer industry.