A third regulator: the TTB
Beyond the FDA and USDA, a third agency governs most alcohol: the Alcohol and Tobacco Tax and Trade Bureau (TTB), part of the Treasury, under the Federal Alcohol Administration (FAA) Act. TTB regulates the labeling of distilled spirits, wines of 7% ABV or more, and malt beverages (beer made with malted barley and hops). For those products, a Nutrition Facts panel is not required.
The FDA slice that DOES need a Nutrition Facts label
Some alcoholic beverages fall outside the TTB's FAA Act authority and under the FDA instead — and those must carry a standard Nutrition Facts label like any other food:
- Wines below 7% ABV — including many hard ciders.
- Beers and fermented beverages not made from malted barley and hops — including many hard seltzers (fermented from sugar) and some gluten-free or sorghum beers.
If your product is in this group, it's an FDA product: build the panel with the Nutrition Facts label generator, just as you would for a food. It's the alcohol counterpart to the FDA-vs-USDA jurisdiction question — same idea, different agency.
What the TTB requires now: mostly voluntary
On TTB-regulated products today, nutrition and allergen labeling is largely voluntary. Since 2013, producers may include a voluntary 'Serving Facts' statement showing serving size, servings per container, alcohol by volume, calories, carbohydrates, protein, and fat. Major-allergen labeling is also voluntary on these products.
What's proposed: 'Alcohol Facts' and allergen disclosure
This may change. In January 2025, the TTB published two proposed rules:
- An 'Alcohol Facts' statement — a Nutrition-Facts-style panel that would be mandatory on TTB-regulated products, disclosing per-serving alcohol, calories, carbohydrates, protein, and fat (sugars optional).
- A major food allergen disclosure — a mandatory 'Contains' statement for the nine major allergens used in production.
As of this writing these are proposed rules, not yet finalized, and the TTB proposed a five-year compliance window from the date any final rule publishes. Treat mandatory Alcohol Facts as coming-but-not-here; the voluntary Serving Facts remains the current option for TTB products. Check the TTB for the latest status before relying on it.
Which agency is my drink under?
| Product | Regulator | Nutrition Facts panel? |
|---|---|---|
| Distilled spirits | TTB | No (voluntary Serving Facts) |
| Wine, 7% ABV or more | TTB | No (voluntary Serving Facts) |
| Malt beverage / beer (barley + hops) | TTB | No (voluntary Serving Facts) |
| Wine under 7% ABV; many hard ciders | FDA | Yes — required |
| Hard seltzer (fermented sugar); non-malt beers | FDA | Yes — required |
When in doubt, confirm your classification with the TTB or the FDA before printing — the ABV and the base ingredients decide it.