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Additional Update from the TTB on Labeling Disclosure for Cochineal Extract and Carmine on Alcohol Labels

Quinta Nova, Ferrão. — in Oporto, Porto, Portugal.

TTB recently announced, in final rule T.D. TTB-103, it is amending labeling regulations to require the listing of cochineal extract and carmine on the label of any alcohol beverage that contains one or both of the color additives. According to the final rule, “[t]his rule responds to a final rule issued by the Food and Drug Administration. Consumers who are allergic to cochineal extract or carmine will now be able to identify and thus avoid alcohol beverage products that contain these color additives.” (See T.D. TTB-103.) TTB indicates this requirement will apply to “products that are removed from domestic bonded premises or from customs custody on or after April 16, 2013; however, voluntary compliance with this final rule, including making any required labeling changes, may begin immediately.” For information on the effective date and the history of this change, see id. For more information on the final rule issued by the FDA, from which this change stems, refer to Listing of Color Additives Exempt From Certification: Food, Drug, and Cosmetic Labeling: Cochineal Extract and Carmine Declaration.

Lindsey A. Zahn


Lindsey is the founder and author of On Reserve: A Wine Law Blog. She is an alcohol beverage and food attorney and is admitted to the New York State Bar.

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