Ask the Collective
The questions independent drinks founders ask most — answered. Distilled from years of community knowledge so the good stuff never disappears in the feed again.
What do I need to know about FDA facility registration when exporting spirits to the US, and should I register my own facility or use my co-packer's registration?
FDA registration is facility-based, not company-based. When exporting to the US, the registration is linked to the actual production site—so if you use a co-packer, their FDA facility registration is what matters. **Key points members shared:** - The FDA requires facility registration (not a separate exporter registration) - If you outsource production, you use your co-packer's FDA number - **Critical for customs:** Ensure the FDA facility registration number appears on all commercial invoices—customs brokers sometimes miss this, which can cause holds at port - Some members offer FDA filing services for their clients as part of their offering **Warning:** Double-check with your customs broker that the facility registration is included on export documentation; this appears to be a common point of failure that delays shipments at US ports.
What is the process and requirements for getting FDA approval to sell beverages in the US and Canadian markets?
Members confirm that FDA approval is achievable but requires specialist support. The community's recommended approach: - **UK Beverage Services** — recommended as a starting point for FDA compliance guidance; members have referred this consultancy to each other for US market entry - **Campden BRI** — can review beverages for compliance requirements One member reported the process "wasn't as hard as we thought," suggesting it's manageable with the right support, but no member in this discussion shared detailed step-by-step protocols or timelines. For kosher certification (often paired with FDA compliance planning), members recommend **Kosher.org.uk**. Note: The discussion shows members actively seeking this information but no one fully documented their FDA approval journey in the excerpts provided.
What are the FDA compliance requirements and practical procedures for shipping alcoholic beverages to the USA?
FDA compliance for exporting alcohol to the US requires registration and a registered importer pathway. Members report the process is complex and involves multiple hurdles. **Key requirements:** - You must register with the FDA website - You need a registered importer in the US to facilitate your shipment - A **Cola Waiver** can be obtained through a registered importer, but this is limited to sample shipments only - Full commercial shipments face stricter approval pathways **What members have actually done:** - Several members have successfully used **MoM** (Malt of Moravia) and **Whisky Exchange** as importers/distribution partners for getting product into the US market - Sample shipments via registered importers have shown mixed success rates (members reported approximately 75% success) - Direct sample shipping without proper channels is unreliable and not recommended **Caveats:** Members consistently characterised the FDA registration and importer system as "a nightmare" and "bit of a nightmare." The Cola Waiver route severely limits what you can ship (samples only), making it unsuitable for commercial volumes. Full commercial import requires significantly more complex compliance beyond just registration.
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.