U.S. Proposes Mandatory Disclosures of Alcohol Facts and Major Food Allergens in the Labeling of Alcohol Beverages

All alcohol beverage labels shall include per-serving alcohol, calorie, and nutrient content information in an “Alcohol Facts” statement. Wines, distilled spirits, and malt beverages labels must declare milk, eggs, fish, crustacean shellfish, tree nuts, wheat, peanuts, soybeans, and sesame, as well as ingredients containing protein derived from these foods, if used in production.

On January 17, 2025, the Alcohol and Tobacco Tax and Trade Bureau (TTB), a bureau of the United States Department of the Treasury, issued two proposals, Notice No. 237 and Notice No. 238, seeking to require alcoholic beverage labels to disclose per-serving alcohol content, nutritional information, and the presence of major food allergens. The comment period for the proposals will be open for 90 days, with feedback due by April 17, 2025.

Alcohol Facts

According to the Notice No. 237, TTB proposes to introduce an "Alcohol Facts" statement on all alcoholic beverage labels regulated under the Federal Alcohol Administration Act (FAA Act). The "Alcohol Facts"statement would disclose critical information per serving, including alcohol content by volume, pure alcohol in fluid ounces, calories, and the grams of carbohydrates, fats, and proteins.

Moreover, the TTB proposes a new requirement for all alcohol beverage labels to include an alcohol content statement, expressed as a percentage of alcohol by volume (ABV). This would apply to table wines (7-14% ABV), malt beverages, and beers, and aims to standardize alcohol labeling across the industry.

Currently, the alcohol content labeling is mandatory for all distilled spirits, wines with alcohol content exceeding 14%, and most malt beverages. Wines with alcohol content between 7% and 14% may optionally display alcohol content, but those exceeding 14% must include it. Certain flavored malt beverages containing alcohol derived from non-beverage ingredients also require alcohol content labeling.

Allergens

According to the Notice No. 237, TTB proposes the mandatory disclosure of major food allergens in alcoholic beverages under the FAA Act. The proposed regulation requires that labels on wines, distilled spirits, and malt beverages must list allergens such as milk, eggs, fish, Crustacean shellfish, tree nuts, wheat, peanuts, soybeans, and sesame, as well as ingredients containing protein derived from these allergens.

If these proposals are approved, a five-year compliance deadline from the publication of the final rule would be set. In the future, all exports of alcoholic beverages to the United States, including wine, liquor, and malt beverages, will need to comply with the new labeling requirements.