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 disclose known allergens could face product liability claims, recalls, and reputational damage, even if it technically complies with TTB’s voluntary framework.

In the European Union, Regulation (EU) No. 1169/2011 makes allergen labeling mandatory for all pre-packaged foods and alcoholic beverages. Every major allergen, including milk, soy, nuts, and cereals containing gluten, must be clearly declared and emphasized, for example in bold or uppercase letters, on both the ingredient list and the product label. The EU approach prioritizes transparency, traceability, and consumer protection, leaving no grey areas.

For producers marketing in multiple jurisdictions, such as the U.S., Latin America, and the EU, it is essential to harmonize label content to meet the strictest applicable standards. Voluntarily aligning with the EU model, even when operating under TTB approval, demonstrates responsibility and reduces compliance risk. A simple statement such as “Contains: Milk, Soy” can make a meaningful difference in consumer safety and regulatory trust.

At TWeE grupo, we help spirits and beverage companies navigate the complex intersection of TTB, INVIMA, EU, GACC, amounts others requirements. Our regulatory and technical experts assist clients in auditing formulations for hidden allergens, drafting compliant ingredient and allergen declarations, designing labels ready for multiple markets, and preparing supporting documentation such as COAs, supplier attestations, and allergen statements. By ensuring global compliance, we help brands protect their consumers, safeguard their reputation, and strengthen their market access.

If you would like to learn more about how TWeE grupo can help your company implement international-ready allergen and ingredient labeling strategies for alcoholic beverages, contact us today.