alcohol beverages generally

There is lots of focus on what the craft people are up to, and certainly there is much movement in that regard. But here we turn back to the big companies, and how they see things. Artisan Spirit magazine recently published my email interview with Tom Lalla. Tom was the head lawyer at Pernod for many years. An excerpt is below, and you can find the full article at the link.

Who were the legendary beverage lawyers before you, and what made them so?

The outstanding, legendary beverage lawyer of the past few generations was Abe Buchman. I worked with Abe and his firm for 10 years and then continued to work with him when I joined Pernod Ricard. Abe was a mentor and a role model for tireless devotion to the industry. Abe taught me the necessity of finding practical solutions for our clients’ issues.  Sometimes, as lawyers, we lose sight of being practical. We get hung up in the legal niceties of an issue. What Abe stressed was that we find a solution that was practical for the client and accomplished the client’s goals without running afoul of the legal requirements. Another legend was Bill Schreiber.  I had the pleasure of working with both Bill and Abe when the Buchman and Schreiber firms...

A recent issue of the TTB Newsletter had some good information about Flavor Ingredient Data Sheets — often referred to as FIDSs. FIDSs can be very important, and so it is good to have this information readily available.

The FAQ explains that a FIDS is typically needed when “you’re using a compounded flavor that was purchased from a flavor manufacturer. … For this purpose, a compounded flavor includes any flavor, cloudifier, or blender that consists of multiple ingredients that are combined to produce a particular taste characteristic.” The same FAQ provides a blank, fillable FIDS form.

The FAQ emphasizes that you should get the FIDS from your flavor supplier; it is not a document that can or should normally be prepared by the producer of the end beverage. The FIDS form first burst onto the scene 20 or more years ago, and has not changed very much in the intervening years. It covers the basics like, is the flavor approved, safe, natural, and does it contain any colors or other ingredients with labeling or safety implications. In an attempt to go a bit beyond where TTB’s document already goes, here are a few common examples of where a FIDS is and is not indicated.

• Cherry Liqueur (made with Natural Cherry Flavor)
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TTB approved this label July 18, 2017. There are very few other TTB labels that mention CANNABIS and SATIVA. Perhaps this product has hemp seeds, along the lines of this 2014 label approval. Then again, perhaps the Lithuanian product merely tastes like hemp or cannabis, as a literal reading of the label would suggest.

Though I see a few signs of cannabis and hemp, in recent approvals, I am not seeing any that mention CBD (aka, cannabidiol). CBD is one of many cannabinoids in cannabis; it is usually viewed as not intoxicating, though it may have various other impacts on brain function. This April 20, 2017 article does a good job of explaining about the barriers to seeing CBD in an alcohol beverage product, or on the label.

Although Dad and Dudes (“D&D,” the Colorado brewer) probably wanted to market something along the lines shown in the photo above, the actual federal approval is quite a bit less adventurous, as in the label image here.

The text near the green arrow, on a related approval, tends to show that D&D grudgingly banished the “additive(s)”.

The article says D&D:

will be fighting the federal government over a beer brewed with non-psychoactive CBD. …

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