Breweries, wineries and distilleries desiring a bit more flexibility to make changes to their products after formula approval – without submitting and waiting on a new or superseding formula to be approved – should use one or all of the following tips when preparing formulas for TTB submission.
1. Alcohol Content and Ingredient Ranges
To account for changes you may want to make down the line, provide broad ranges for ingredients and the finished alcohol content of your product.
2. Optional Ingredients
If you are on the fence about whether to include a particular ingredient in your product, you can list it as optional, provided its inclusion or exclusion does not impact labeling. This tip tends to be especially helpful when creating formulas for gin, allowing distillers the flexibility to use any number of botanicals to tweak their recipes.
3. Genericize Ingredients
Do not give overly specific details about ingredients when possible. For instance, listing “Washington Braeburn Apples,” “Galaxy Hops” or “Madagascar Bourbon Vanilla Beans” in your formula will lock you into using those exact ingredients until/unless you amend your formula. Instead, simply list “Apples,” “Hops” or “Vanilla Beans” and you will be able to use any variant of those ingredients without issue.
For more information about this topic, contact John Messinger.
