Understanding Allergen Labeling Rules from TTB to EU
Across global markets, allergen labeling for alcoholic beverages remains one of the most misunderstood and most overlooked regulatory topics. While allergens such as milk, soy, nuts, and eggs are common in cream liqueurs, flavored spirits, and ready-to-drink cocktails, the obligation to declare them varies dramatically depending on where the product is sold. In the United States, alcoholic beverages are regulated by the Alcohol and Tobacco Tax and Trade Bureau (TTB), not by the Food and Drug Administration (FDA). Although the Food Allergen Labeling and Consumer Protection Act (FALCPA) establishes mandatory allergen disclosure for foods, TTB’s allergen program is voluntary. This means producers can choose whether or not to include allergen information on their labels, but the absence of a legal requirement does not eliminate legal exposure. Under U.S. case law, such as Wyeth v. Levine, manufacturers still have a duty to warn consumers of foreseeable risks. A brand that fails to disclos...
