Hello, and welcome to the Grace Regulatory Consultants blog! This is where I will fill you in on important regulatory matters such as updates on regulatory changes, explanations of more complex issues, reviews of the basics, discussions of current events or answers to common questions. If you have something that you would like me to address, just let me know.
For starters, let's take a look at one of my favorite subjects: cider. Specifically, what is it? While the industry may have a clear idea what cider is, regulators have about as many definitions as there are states. Even the federal regulators, TTB, have two different meanings for cider: one for taxes and the other for labeling.
What do most of these definitions have in common? Cider is a type of wine. This may be surprising to some because cider is often bottled, packaged and marketed as beer. Some of the most well known ciders are even made by breweries. Despite this, most states and TTB classify cider as a wine because it is made from fruit.
What does this mean? Winery licensing, wine label regulations and wine taxes, of course. All of those breweries making cider must also secure a winery basic permit from TTB and a winery license from their state. Depending on the nature of the operations (separate or shared facilities for beer and cider) and the state, this could be fairly straightforward or next to impossible.
Labels for most ciders (those under 7% alcohol) must comply with a combination of TTB and FDA regulations. This creates unique challenges for folks that are used to dealing only with TTB for beer or wine labels. On the plus side, these ciders do not need label approval from TTB.
Cider taxes are a subject for another post because TTB's wine taxes are rather complicated. Oregon's cider taxes are also a little weird, because despite what I said above, OR taxes cider as a malt beverage. Did I mention that cider regulations are a bit complicated?
I will cover more about cider in future entries. In the meantime, please send me questions or comments. I look forward to hearing from you,
Janene
For starters, let's take a look at one of my favorite subjects: cider. Specifically, what is it? While the industry may have a clear idea what cider is, regulators have about as many definitions as there are states. Even the federal regulators, TTB, have two different meanings for cider: one for taxes and the other for labeling.
What do most of these definitions have in common? Cider is a type of wine. This may be surprising to some because cider is often bottled, packaged and marketed as beer. Some of the most well known ciders are even made by breweries. Despite this, most states and TTB classify cider as a wine because it is made from fruit.
What does this mean? Winery licensing, wine label regulations and wine taxes, of course. All of those breweries making cider must also secure a winery basic permit from TTB and a winery license from their state. Depending on the nature of the operations (separate or shared facilities for beer and cider) and the state, this could be fairly straightforward or next to impossible.
Labels for most ciders (those under 7% alcohol) must comply with a combination of TTB and FDA regulations. This creates unique challenges for folks that are used to dealing only with TTB for beer or wine labels. On the plus side, these ciders do not need label approval from TTB.
Cider taxes are a subject for another post because TTB's wine taxes are rather complicated. Oregon's cider taxes are also a little weird, because despite what I said above, OR taxes cider as a malt beverage. Did I mention that cider regulations are a bit complicated?
I will cover more about cider in future entries. In the meantime, please send me questions or comments. I look forward to hearing from you,
Janene
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