Naming nonbeverage products
- Natural Flavors: must contain a natural source of the named material and must be an all-natural product. Any flavor materials present must be derived from the named ingredient. For example, a natural strawberry flavor must contain a natural source of strawberry and all flavor materials must be derived from strawberry.
- Natural Flavors WONF: must contain a natural source of the named material but may also contain other natural flavor materials. These other natural flavors do not need to be derived from the named material. For example, a natural strawberry flavor WONF must contain a natural source of strawberry but may also contain natural flavor chemicals not necessarily derived from strawberry (e.g. natural ethyl butyrate).
- Natural & Artificial Flavors: must contain a natural source of the named material but may also contain artificial flavor materials.
- Natural Type Flavors, Natural Bases and Natural Keys: natural flavors that do not contain the named ingredient. For example, natural strawberry type flavor contains all natural ingredients but does not contain a natural source of strawberry.
- Natural & Artificial Type Flavors: contains both natural and artificial ingredients but does not contain a natural source of the named ingredient.
- Artificial Flavors: predominant flavor is from artificial ingredients.
NOTE: Any products containing artificial ingredients cannot have “WONF” in the name!
- Natural & Artificial Flavors with 0.1% artificial topnote: flavors containing not more than 0.1% artificial topnote are considered natural when used in alcoholic beverages. The calculation of the amount of artificial material does not include artificial vanillin, ethyl vanillin, artificial maltol nor ethyl maltol.
- When flavors are submitted for drawback of tax, the name should comply with the above TTB requirements (i.e. Natural & Artificial) even though some (Natural & Artificial Flavors with 0.1% artificial topnote) may be considered natural when used in alcoholic beverages.
- Natural & Artificial Flavors with greater than 0.1% artificial topnote: considered for alcoholic beverage labeling purposes to be artificial.
- Other considerations: TTB has limitations for artificial vanillin, ethyl maltol, artificial maltol and ethyl maltol in alcoholic beverages. If these limitations are exceeded, the finished beverage will be considered an artificial product.
Vanillin: 40 ppm
Ethyl vanillin: 16 ppm
Maltol: 250 ppm
Ethyl maltol: 100 ppm
** Keep in mind that these limitations are in the finished alcoholic beverage; not in the flavor. The actual amount present in the beverage will be calculated based on the use rate of the flavor.
- Wines containing < 7% by volume ethanol are subject to the FDA labeling guidelines listed above.