Even non-alcoholic malt beverages can still get you in hot water with the Alcohol and Tobacco Tax and Trade Bureau (TTB).
As with standard beer, there are several labeling regulations for malt beverages that contain 0.5 percent alcohol by volume or less. Both alcoholic and non-alcoholic beer laws have some regulatory crossover, but it’s important not to follow all the same labeling rules for your less boozy beverages. Let’s break down some key differences that will impact your non-alcoholic beer labels.
Don’t Call Your Non-Alcoholic Malt Beverage “Beer”
Some people may informally call non-alcoholic malt beverages “beer,” but federal regulators certainly do not. The TTB defines beer as a beverage that contains “one-half of one percent or more of alcohol by volume, brewed or produced from malt, wholly or in part, or from any substitute for malt.”
Even if your product is produced from malt and contains 0.5 percent alcohol or less, it would instead be considered a “cereal beverage.” Because of these definitions, non-alcoholic beverages cannot be legally labeled as beer. Your label also cannot reference any other class or designation types associated with beer. These include, but are not limited to:
- Malt liquor
Do Use the Correct Class Designations for Non-Alcoholic Beverages
While you can’t label your non-alcoholic drinks as beer, you still need a class designation for your labels. There are a few different terms for products containing less than 0.5 percent alcohol by volume.
- Malt beverage
- Cereal beverage
- Near beer
According to the Electronic Code of Federal Regulation (27 CFR 7.24), these words must all appear on the same label panel (no splitting the words between different backgrounds). Additionally, they must be in the same size, style of type, and color of ink.
Don’t Mix up Regulations for “Non-Alcoholic” and “Alcohol Free” Statements
Even if your product is non-alcoholic by definition, you still need an alcohol content statement. This statement operates a little differently than regular beer labels that must list the exact alcohol content to the nearest 0.1 percent. However, the exact rules depend on whether your beer is non-alcoholic or alcohol free.
While the term non-alcoholic may sound like there’s no alcohol in your beverage, it technically applies to drinks with an ABV of less than 0.5 percent. You are allowed to include the words “Non-Alcoholic” on your label as long as that same label also states “Contains less than 0.5% alcohol by volume.”
Any label that contains an alcohol content statement of 0.0 percent alcohol by volume must also state “alcohol free.” One catch here is that the TTB requires a laboratory sample analysis for formula approval per TTB G 2016-1A. As such, don’t be surprised to hear from the TTB if you submit a label making an alcohol free claim.
Do Include Specific Tax Language
Another quirk involving non-alcoholic malt beverages is that they aren’t subject the same taxes as their boozier cousins. Because of this, the TTB mandates that non-alcoholic malt beverages must add some special verbiage on their labels per 27 CFR 25.242. This statement should read “Non taxable under section 5051 I.R.C.”
Don’t Worry About the Government Warning
Typically, beer labels must include a health warning statement. Non-alcoholic beverages are not your typical beer (or by TTB definitions, not beer at all). Since the health warning statements are aimed to warn about the presence of alcohol, non-alcoholic drinks don’t need to include these statements on their labels.
Do Follow Additional FDA and TTB Regulations Beer Regulations
Non-alcoholic malt beverages have some different regulations from beer, but there are some requirements they do share. Certain details are mandatory for any type of malt beverage, whether it contains alcohol or not. These include, but are not limited to:
- Brand names
- Net contents
- Name and address
The TTB is very specific when it comes to not only what you say on a label, but also how you present that information. As such, you’ll need to follow these guidelines to make sure you label is compliant with the TTB. For more information on these requirements, check out our post on TTB malt beverage label requirements.
Don’t Skimp on Your Design
It’s no secret that there are a lot of regulatory information that dictates what you can and can’t put on your labels. However, there’s no rule against making your packaging look great.
Whether you need can wraps or bottle labels, it’s essential to make sure your products stand out from the crowd. The right splash of color or an eye-catching design is an essential part of any successful beer label, non-alcoholic or not. At Blue Label, we have the expertise and state-of-the-art equipment to enhance your designs.
Ready to invest in the quality, cost-effective labels for your non-alcoholic malt beverages. Contact us today to get the labels your products need to succeed.