On September 29, the Alcohol & Tobacco Tax & Trade
Bureau (TTB) issued two new Rulings announcing the creation
"general use formulas" for certain distilled spirits and
agricultural wines. These general use formulas permit the
production or importation of these products without the need to
first obtain an approved formula (for domestic products) or a
pre-import approval (PIA – for imported products) from
TTB Ruling 2016-2 exempts from the regulations' formula and
PIA requirements most "agricultural wines," a category
that generally encompasses wines fermented from materials other
than fruit. Most notably, honey wine (mead) is now exempt from the
requirement to file for a formula or a PIA prior to applying for
label approval and/or introducing the product into commerce.
TTB Ruling 2016-3 exempts certain categories of distilled
spirits from formula and PIA requirements. For certain categories
of spirits made with less than 2.5 percent "harmless coloring,
flavoring, or blending materials," certain specific materials
are now authorized without the need to obtain formula or PIA
approval. The categories and materials are:
Vodka made with sugar (up to 2g per
liter) and/or citric acid (up to 1 g per liter);
Rum made with sugar, brown sugar,
molasses and/or caramel;
Certain types of whiskies made with
sugar, caramel and/or wine; and
Certain types of brandy made with
sugar, caramel, fruit from the same fruit used to make the brandy
and/or wine fermented from the same fruit.
These changes represent a modest but helpful attempt to reduce
the number of formula and PIA submissions filed by the
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