Several bottles of kombucha with labels that meet legal requirements sitting in a large bucket of ice outdoors.

Everything You Need to Know About Kombucha Label Requirements

Whether it’s due to its love-it-or-hate-it taste, perceived health benefits, or novelty among less-natural beverages, there’s no question that kombucha beverage sales are skyrocketing. Over the past 15 years, the market for this fermented tea has grown from almost nothing to over $1.5 billion in annual sales. There are even hard kombucha products entering the market as a gluten-free alternative to hard seltzers and beer. 

While this fermented beverage has been around for centuries, it’s hard to classify. Is it a soft drink? A supplement? An alcoholic beverage? With so many possibilities, how can you be sure your custom kombucha labels comply with labeling requirements? 

Am I Selling Alcohol or Non-Alcoholic Soft Drinks, and Does it Matter?

Alcohol is a natural byproduct of the fermentation process. If your product contains 0.5 percent alcohol or more by volume, it’s considered an alcoholic drink. Products that have less than 0.5 percent alcohol by volume are non-alcoholic drinks.

You may think alcoholic drinks are automatically under Alcohol and Tobacco Tax and Trade Bureau (TTB) regulations. However, the Food and Drug Administrations (FDA) has jurisdiction over sugar brews and wine that contains less than 7% alcohol. If you only use sugar during fermentation, your product is a sugar brew. If you use any fruit juice to ferment the beverage, it’s a wine. Making malted beverages? Those are considered beers and fall under TTB regulations. To add to this confusion, some states require beverage makers to follow TTB labeling regulations for all alcohol beverages, no matter who has jurisdiction at the federal level.

In the past, the FDA has pulled fermented beverages from the marketplace in the past for containing alcohol levels that were too high. If you’re making a low alcohol content beverage, you need to stay on top of testing to make sure you’re keeping the amount of alcohol within legal limits.

Meeting TTB Kombucha Packaging Guidelines

If your product falls under TTB rules, your labels need a Certificate of Label Approval (COLA) that follows the requirements in the Beer Beverage Alcohol Manual (BAM). This label must include the following:

  •  The name and address of the brewer, importer or distributor
  • Ingredient disclosures for saccharine, sulfides, FD&C Yellow No. 5 and aspartame
  • Net contents by volume
  • Class and designation, as categorized in the BAM. If your beverage contains malt, it’s categorized as a “malt beverage.”
  • A government health warning

The product’s alcohol by volume (ABV) must be included on the label. Alcohol by weight (ABW) may also be required by some states.

TTB labels don’t have a “Nutrition Facts” panel, but you have the option of adding a “Serving Facts” panel, like those used on some beers. (This panel lists macronutrient values, including calories, carbohydrates, protein and fat.)

Food and Beverage Regulatory Guidelines 

FDA bottling and labeling standards are covered by the Federal Code of Regulations 21 CFR 101. These labels have three main parts:

  • A nutrition facts panel
  • An ingredient list
  • A declaration of allergens

The front panel, which covers at least 40% of round containers, must list a generic name and the volume of the beverage. 

How Do Kombucha Brewers List Sugar Content?

In 2016, the “Added Sugar” category was added to “Nutrition Facts” labels. What counts as added sugar in a product that requires sugar for fermentation?

Sugar content is measured after fermentation, so only some of the sweetener you add counts. 

Added sugar is what you add to the drink after fermentation. Added sugar cannot exceed total sugar content, and you have to account for the loss of sugar caused by fermentation. In other words, you need to measure the amount of sugar in the final product, then calculate how much was lost during fermentation to get the numbers you need for the label. 

What Health Claims Can I Make?

This beverage’s current popularity is driven in part by perceived health benefits. These beliefs can vary widely, from digestive benefits brought by probiotics to claims of treating cancer. However, when it comes to product labeling, you have to follow strict rules laid down by the FDA. These claims fall under three categories:

Authorized health claims: These claims meet the Significant Scientific Agreement (SSA) standard, and statements are shown to be supported by publicly-available scientific evidence. You can find a list of approved claims here.

Qualified health claims: These claims don’t meet SSA standards, but are still backed by some significant scientific studies. Qualified health claims usually start with “Scientific evidence suggests, but does not prove…” You can find a list of FDA-approved claims here. 

Nutrient content claims: These claims are based solely on the nutrients in your product. Such claims use phrases like “Free,” “High in,” “Good source of,” and “Enriched with.” The FDA has strict guidelines on these claims, covered in the FDA Food Labeling Guide, Appendix A: Definitions of Nutrient Content Claims.

Organic Certification

Organic labeling is handled by the USDA’s National Organic Program (NOP). To qualify, your beverage must be approved by a USDA-approved organic certifying agent. But, how you state this certification depends on the amount of organic content in your beverage.

Organic: At least 95% of ingredients excluding water and salt are organic. Non-organic ingredients can’t be used if there is a commercially-available organic version.

Made with organic ingredients: If the product is at least 70% organic, the label can carry the statement “Made with organic” followed by one to three ingredients.

Specific organic ingredients: Anything below 70% organic can only state which ingredients are organic on the “Nutrition Facts” label. For example, you can list NOP-certified honey as “organic honey.” 

Getting Your Custom Kombucha Labels Onto Your Containers

While glass bottles are a popular choice for packaging these beverages, cans are also a viable option, even for small producers. If you want to see how a can wrap system can fit your production system, watch our video with Birdfish Brewing Company. 

The same process we used to build a labeling system for their beer can be applied to your beverage cans. And, you may find the increased recycling and reduced shipping costs of aluminum cans are a good fit for your business and your brand. 

Our 360a WR Wrap System is perfect for can wrapping. This machine applies labels to a range of round containers, and it can switch between several pre-calibrated label configurations. This makes it possible to use one machine for several sizes of containers, from slim cans to tall boys.

Want to package your products in bottles? Our Vertical Trunnion Roller labeling system is designed to accurately apply multiple labels to round bottles. Originally designed for top-shelf bourbon, this machine can be set up to apply up to 5 labels on every bottle. (This includes neck labels and tamper-evident labels over caps.) This flexibility lets you emphasize label graphics, or leave parts of the bottle uncovered, so customers can see inside.

We Have the Equipment You Need for Efficient Quality Labeling

Whether you want to upgrade your production process, or you’re just entering the kombucha tea beverage market, CTM Labeling Systems has labeling machines that fit your needs.  

In addition to helping you navigate the complexities of kombucha label requirements, our local distributors will work with you to set up a labeling system that keeps pace with your production lines, maximizing efficiency while reducing label errors and damaged products.

Get the finished products you’ve been wanting with trusted labeling applicators from CTM Labeling.    

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