Testing Guidelines and FAQ on Alcohol

ABOUT KOMBUCHA

Alcohol as a Characteristic of Kombucha

• The combination of sugar and yeast triggers fermentation, which may produce a kombucha with an alcohol content of 0.5% or more alcohol by volume.
  
  
• Fermentation, which is part of kombucha production, is a natural reaction when sugar and yeast are combined. Factors can influence how much alcohol is produced by fermentation with time & temp.
  
• Even though a kombucha beverage may have less than 0.5% alcohol by volume at the time of bottling, fermentation may continue in the bottle after it leaves the production facility, depending on how the kombucha beverage is made and stored. As a result, the alcohol content may increase to 0.5% or more alcohol by volume.

Federal Guidelines

• Under federal law, if the alcohol content of Kombucha is 0.5% or more alcohol by volume, at any time during production, when bottled, or at anytime after bottling, the kombucha is an alcoholic beverage and subject to TTB regulations.
  
• If Kombucha is NEVER at or above 0.5% alcohol by volume during production, at time of bottling, or after bottling - TTB REGULATIONS DO NOT APPLY. This type of kombucha must comply with all applicable Food and Drug Administration (FDA) regulations. 

Wine Labeling Requirements

• Brand name, Class type, Name address, Net contents and Alcohol content
  
• A statement that contains the product contains FD&C Yellow No. 5, where the coloring material is used in a product bottled on or after October 6, 1984
  
  
• Declaration of cochineal extract or carmine - a statement that product contains the color additive using common names cochineal extract or carmine
  
  
• Declaration of sulfites
  
• Voluntary disclosure of major food allergens
  
• Alcoholic content shall be stated in the case of wines containing more than 14 percent of ABV and If less than 14% listed as table wine

Distilled Spirits Labeling Requirements

• Brand Name, Class type, Alcohol content, Name and address, Net contents
  
• Disclosure of certain ingredients , Coloring or treatment with wood, Age
  
• State of distillation
  
  
• FD&C Yellow 5 must be stated
  
• Cochineal extract or carmine – needs to be listed
  
• Sulfites – need to be listed
  
• Aspartame – need to be listed as % ABV
  
• The alcohol content in degrees of proof may be stated
  
• Coloring materials – artificially colored must appear on label of any distilled spirits product containing synthetic or natural materials that primarily contribute to color
  
  
• Allergen statements – voluntary disclosure

What should I do if I’m not sure about the alcohol by volume?

• Producers who are unsure of the alcohol content of their kombucha may have it tested, using any method that has been formally validated or is otherwise scientifically valid for purposes of determining the alcohol content of beverages, including beverages that contain less than 0.5% alcohol by volume. A scientifically valid method is, among other things, accurate, precise, and specific for its intended purpose, and it has results that are consistently reliable, accurate, and reproducible.

Does the inclusion of an "Alcohol Facts" statement on my label satisfy any applicable regulatory requirements for an alcohol content statement?



• The TTB labeling regulations require an alcohol content statement, expressed as a percentage of alcohol by volume, for certain products. Because the Alcohol Facts statement includes a statement of the percentage of alcohol by volume, it will satisfy those requirements as long as it complies with the placement and type size requirements set forth in the regulations.