Flavoring registration with the TTB: requirements, process, and regulatory scope

The Alcohol and Tobacco Tax and Trade Bureau (TTB) regulates alcoholic beverages in the United States, but its jurisdiction goes beyond just alcohol-containing products. Certain ingredients used in formulations, such as flavorings and extracts, can affect a product’s tax classification and regulatory status. For this reason, the TTB requires registration and approval of flavorings before a product can be legally marketed.

Why must flavorings be registered with the TTB?

Flavoring registration is necessary because its composition can alter the classification of an alcoholic beverage, impacting both taxation and labeling requirements. Some flavorings contain ingredients that can affect the alcohol content, color, or chemical composition of the final product. Additionally, certain additives may be subject to usage restrictions or labeling disclosure requirements.

If a flavoring is not registered with the TTB or does not comply with regulations, the formula approval of the final beverage could be rejected. This may lead to launch delays, reformulation costs, and additional registrations.

Are all flavorings approved or are there restrictions?

Not all flavorings can be freely used in alcoholic beverages without review. While some flavorings have already been pre-approved by the TTB, others require specific documentation to demonstrate compliance with regulations.

Common restrictions include:

• Alcohol content: Flavorings containing alcohol may require declaration on the final product label.

• Restricted ingredients: Certain natural or synthetic compounds may be limited or prohibited due to health risks.

• Impact on tax classification: If a flavoring changes the category of the beverage (e.g., turning a wine into a liqueur), it could alter its federal tax rate.

Ensuring that the flavoring is approved or eligible for registration is critical to avoid delays or compliance issues.

Who must register flavorings and what does the process involve?

Typically, the flavoring manufacturer or supplier is responsible for registration. However, if an alcoholic beverage manufacturer uses an unregistered flavoring, they may need to provide detailed information about its composition and safety.

The registration process generally includes:

1. Ingredient review: The manufacturer submits a full list of ingredients and documentation proving compliance with safety regulations.

2. Assessment of tax classification impact: The TTB evaluates whether the flavoring affects the tax category of the final product.

3. Approval and registration number assignment: If compliant, the TTB issues a registration number for the flavoring, which can then be used by other manufacturers without requiring a new approval.

In some cases, the manufacturer of the flavoring or the beverage company may also need to obtain a TTB facility registration, especially if handling regulated ingredients that influence the final product’s classification.

Why does the TTB regulate non-alcoholic products?

While the TTB primarily focuses on alcoholic beverages, it also oversees certain non-alcoholic ingredients that affect taxation or marketing of taxable products. Examples include:

• Syrups

• Concentrates

• Pre-mixes used in alcoholic beverages

The TTB ensures these ingredients do not compromise compliance, working alongside the FDA to verify that all ingredients are safe and meet both labeling and formulation regulations.

The importance of expert guidance

Flavoring registration is a technical process that can impact formula approval. Incorrect or incomplete documentation can lead to significant delays and extra costs.

At CORE, we help your company:

• Register flavorings with the TTB

• Ensure full compliance during formula approval

• Optimize the registration process to avoid unnecessary delays

Contact us today to ensure your flavorings are approved and your products reach the U.S. market without complications.