Allergen Labeling. The age-old wine label is getting more complicated by the year what with Organics, Meritage, Import Certification — and the new allergen labeling requirements.
Allergen Labeling is on the way – On July 26, 2006, TTB began allowing allergen information on labels for beer, wine and spirits. For now and the next several months at least, allergen labeling is voluntary. But if you elect to make any reference to any of the eight “major food allergens,” you would need to comply with the interim rule, and you would probably need to get a new label approval. The “major food allergens” are: milk, egg, fish, shellfish, tree nuts, wheat, peanuts, soybeans, and their proteins. The interim rule does not seem to have any special treatment if producer is very small, or if the amount of the allergen is very small. By way of example, many wines contain fish proteins as a fining agent. The bottler is not required to say anything about these proteins under current rules, but if the bottler elects to say anything about allergens, the bottler would need to list every allergen in the wine, as CONTAINS: FISH. This could be on any label (front, back, side, neck). By the same token, if you describe your product as WHEAT BEER rather than BEER, you would probably need to get a new label approval and declare CONTAINS: WHEAT on the label.
- Interim rule. Effective July 26, 2006. This is largely voluntary.
- Notice of Proposed Rulemaking. This would take something close to the interim rule and remove the voluntary aspect. It is likely to take months or years before it becomes final, even though there is little organized opposition.
- See an overview of the new requirements prepared by an experienced colleague.
- Let us know when you see examples of new labels, with allergen declarations, and we will post some examples here.