By Lindsey A. Zahn, Esq.
Saturday, October 24, 2026 On Reserve A Wine Law Blog, Cellared Since 2010 Subscribe
Federal Law

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.

DISCLAIMER: This blog post is for general information purposes only, is not intended to constitute legal advice, and no attorney-client relationship results. Please consult your own attorney for legal advice.

This post is for general information purposes only and is not legal advice. Reading it does not create an attorney-client relationship.

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