What are the TTB submission requirements for non-alcoholic spirits with 0.5% ABV in the USA?
For non-alcoholic spirits at 0.5% ABV in the US, TTB formula and label submission is not always mandatory. Members' experience shows two approaches:
- **TTB formula and label submission** — Some producers submitted both when initially launching (e.g. New London Light at launch), but found it may not be necessary for subsequent releases. - **FDA submission only** — On follow-up releases of similar products, members found they only needed to submit to the FDA, not the TTB, suggesting TTB review is less of a blocker now that non-alcoholic spirits are more established in the market.
The consensus indicates that as non-alcoholic spirits have become more mainstream, TTB involvement has become less routine. However, members who submitted to TTB "belt and braces" early on did not report negative outcomes, so the approach may depend on product specifics and risk tolerance. For the most current guidance, direct contact with TTB or a spirits regulatory consultant is recommended.
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