When the TTB has a reminder, it’s a good idea to listen. In their latest newsletter, the TTB reminds brewers that regulations do not require a brewer to obtain a certificate of label approval, or COLA, for a domestically bottled malt beverage that will be sold exclusively in the state in which it was bottled, but the formula approval requirements do apply regardless of whether the beer will be sold in intrastate or interstate commerce. This means that a beer sold only at a taxpaid “tasting room” affiliated with your brewery may be subject to TTB formula approval.
Before applying, first check to see if the beer you are making requires TTB formula approval – not all beers do. Generally, a formula is required if you use ingredients or processes that are not traditional in the production of fermented beverages designated as “beer,” “ale,” “porter,” “stout,” “lager,” or “malt liquor.” We update the list of traditional ingredients and processes from time to time, based on petitions usually submitted by the brewing industry.
To learn more about when a formula is required for beer, see the following guidance:
This online tool leads you through a series of questions about your product to guide you to the answer
View charts that explain which beers need formula approval
This ruling provides information about how we have exempted certain ingredients and processes from formula requirements because we consider them “traditional.” Attachment 1 contains the actual list of ingredients and processes associated with the ruling.