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Selling it

What federal law requires on the label

Updated

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A beverage label carries more mandatory content than most food labels, and one item on it is specific to this category.

The core list

Statement of identity: what the product is, on the principal display panel.

Net quantity of contents, by volume, with metric alongside, in the bottom thirty percent of the principal display panel.

Ingredient list, in descending order by weight.

Allergen declaration, where a major allergen is present.

Nutrition labeling, which for beverages has its own serving size rules and gets its own page.

Name and place of business of the manufacturer, packer or distributor.

Plus a batch code, not required and the thing that makes a problem traceable.

The warning statement

The item specific to this category.

Packaged fruit or vegetable juice that has not been processed to prevent, reduce or eliminate pathogenic microorganisms must carry the warning statement.

It survives the HACCP retail exemption: a producer selling only direct to consumers is exempt from the HACCP rule and is not exempt from this.

Which makes it often missing item on a small producer's label, because the exemption is better known than the obligation that outlives it.

Allergens

Less obvious in a drink than in a food and entirely real: tree nuts in a nut milk, sesame, soy in some additives, dairy in anything cream-based, and wheat in some flavorings.

Shared equipment raises a cross-contact question that deserves a deliberate answer rather than a blanket disclaimer.

What forces a reprint

A reformulation that reorders the ingredient list.

A change of size, which changes the net quantity and often the serving declaration.

Starting or stopping a treatment, which adds or removes the warning statement.

Crossing 0.5 percent alcohol, which changes the label regime entirely.

And an address change, which catches everybody.

References

US Food and Drug Administration. Food Labeling Guide, including the nutrition labeling and serving size rules that apply to beverages. fda.gov
21 CFR 101.7, Declaration of net quantity of contents. ecfr.gov
US Food and Drug Administration. Exemptions from the Warning Label Requirement for Juice. A retail establishment selling juice directly to consumers and not distributing to other businesses is exempt from the HACCP rule, and untreated juice must still carry the warning statement. fda.gov
Alcohol and Tobacco Tax and Trade Bureau. General TTB Requirements for Kombucha. Production on premises qualified under the Internal Revenue Code, compliance with labeling, formula and tax requirements, and the health warning statement required by the Alcoholic Beverage Labeling Act of 1988. ttb.gov
Written from the federal regulation and agency guidance named on each page, not from a laboratory. Whether a particular product meets a pathogen reduction requirement, and what its alcohol content actually is, are measurements about your product, and this is not those measurements.