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)
- Get a FIDS for the cherry flavor
- Cherry Liqueur (made with cherries)
- Don’t bother with the FIDS because, as above, the FIDS is intended to be used with compounded flavors
- Cherry Liqueur (made with artificial flavor)
- Trick question because liqueurs must contain at least one natural flavor and can’t contain any artificial flavors, so the FIDS is not going to help here
- Straight Bourbon Whiskey
- If you have a FIDS you are probably going in the wrong direction because this category should not have anything added
- Malt Beverage with Natural Cherry Flavor
- Needs a FIDS
- Malt Beverage Brewed with Cherry Juice
- Does not need a FIDS or a formula approval. Does not need a formula approval due to the tremendously important liberalizations at TTB Ruling 2015-1 and the accompanying list of exempt ingredients and processes. Does not need a FIDS because the juice is not compounded.
- Grape Wine with Natural Cherry Flavor and a Cloudifier
- You need a FIDS for the cherry flavor, and for the cloud. Even though the cloud is not really a flavor and probably does not need to be mentioned on the label, it does need a FIDS because it’s probably compounded (of various ingredients) like a flavor.
As soon as you start talking to your flavor company, it’s worth asking which flavors do and don’t already have a FIDS. That’s because if you need one, but the flavor company does not have one yet, it could take them quite a few weeks to get the TTB flavor approval needed as a foundation for the FIDS. You should not assume all flavors have a FIDS because not all flavors are made in the US, or intended for use in alcohol beverages, where the above rules most directly apply. As yet one more example, if you are making pickle-flavored potato chips in Parguay, you probably don’t need a FIDS or a TTB formula approval.