I am not going to the store as often as I used to — but when I do — I can’t escape the cavalcade of RTD spirits cocktails. That’s good for Flavorman and other formulators. It’s also good for our firm because it’s a lot of work, compared to when something similar is prepared at a bar or your home.
Earlier this year I talked this over with one of the premier flavor companies and alcohol beverage formulators out there. The full article is here and a hefty excerpt is here:
Canned spirits cocktails are one of the biggest trends at TTB in recent years. Even though the explosion of hard seltzers probably gets more attention, TTB approved more than 370 ready-to-drink (RTD) spirits labels for margaritas in just the past five years. This is to say nothing about the many other well-recognized RTD cocktail types, such as bloody marys, martinis and so forth.
The purpose of this article is to give you a heads up that it can be surprisingly painful to get such products approved. Every time we say we’ve handled scores of grasshoppers, for example, in the past, we are in for new and unpleasant surprises, to the extent we start to think it’s routine. I will run through some of the most common reasons why.
“Recognized Cocktails”
First off, TTB keeps a quaint old list of “recognized cocktails” here. This list does not do an especially good job of recognizing that cocktails come and go like fashion, and there are many modifications upon even the most enduring themes.
The current list covers only a couple dozen cocktails and these are the ones that were popular when your father was young: cocktails like the grasshopper, apricot sour, mai tai, pink squirrel, and others.
If, perchance, your intended cocktail is on the list, TTB will be rather fierce about requiring you to include a few more or less random ingredients. For example, if you mention Margarita, the BAM guidelines require you to include at least the following ingredients: Tequila, triple sec, and citrus.
It’s no big deal until – maybe 14 weeks into a 10-week timeline, you realize there is no triple sec in your product. This could cause pain not limited to, going all the way back to square one to find a triple sec, redo the formula and wait for it, and resubmit the label application (and then wait some more). TTB makes various exceptions from time to time, so this only makes the adventure more treacherous. Once your Margarita is all set, if you are making a wallbanger, don’t forget the Galliano or similar.
Let us know if you have any questions about how to launch your own canned cocktails.
Always great information, Robert. Thank you.
Hi, what is the regulation of the labeling of the RTD cocktails specifically around the sugar content? Most FDA required labels must have the sugar, added sugar and the % of daily value however these are not on the RTC cans or packaging, that I have seen.
The rules are very different on this, as between spirits cocktails and foods without alcohol. On such RTDs there is no ingredient labeling, sugar labeling, % of daily value, etc.
So spirit cocktail labeling wouldn’t have an agency to follow up with then? or would it fall under FDA or TTB? or another agency?
TTB would review and approve the formula and label pre-market.