On December 23, 2014, FDA issued final guidance on the labeling of certain non-malt beers, which are subject to FDA labeling requirements after a 2008 ruling by the Alcohol and Tobacco Tax and Trade Bureau declared that beers not meeting the definition of "malt beverage" are not subject to Federal Alcohol Administration Act labeling provisions. In this guidance, FDA clarifies that non-malt products must conform to FDA labeling regulations, including, among others, the requirement for a statement of identity, ingredient declaration, nutrition facts panel, and appropriate allergen labeling. Additionally, the Government Health Warning Statement under the Alcoholic Beverage Labeling Act continues to apply to these products. This guidance was issued in draft form in 2009, at which time FDA allowed manufacturers until January 1, 2012, to revise non-malt beer labels. The final guidance explains that all labels for these products should now comply with all applicable laws and regulations.
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