Affected US alcohol beverages must remove FD&C Red No. 3 by January 15, 2027

On November 6, the Alcohol and Tobacco Tax and Trade Bureau said producers and importers must ensure that color additives in alcoholic beverages comply with Food and Drug Administration rules. As the Department of Health and Human Services and the FDA work with companies to remove petroleum-based synthetic dyes from food, FD&C Red No. 3 will cease to be permitted in foods, including alcoholic beverages. Companies have until January 15, 2027 to reformulate affected products and obtain an approved formula that meets federal requirements.¹

Rules for colors and revised formulas

The notice applies particularly to brewers, winemakers, distillers and importers that add color to products requiring formula approval, including flavored malt beverages, specialty spirits and other alcoholic drinks. Commercial availability alone does not make a color additive permissible: the FDA must approve it, and the authorization must cover its use in the relevant alcoholic product.¹

Some additives approved broadly for food may also be used in alcoholic beverages. More narrowly authorized colors are permitted only for the products or purposes specified in their regulations. TTB said an additive can be used in an alcoholic drink when it is approved for food generally or when its regulation expressly includes coloring alcoholic beverages. Questions about federal approval and petitions for colors derived from natural sources should be directed to the FDA.¹

The FDA has approved new additives from natural sources during the move away from petroleum-based synthetic dyes, although TTB named no particular substitute in its notice. Producers considering reformulation were advised to consult FDA resources. TTB’s Alcohol Labeling and Formulation Division can address product classification and the use of a particular color in a specific beverage, while its Scientific Services Division handles assistance concerning nonbeverage products.¹

Updated Italian seals for DOC and DOCG wines

The same TTB newsletter told importers that Italy is gradually introducing redesigned official state seals for DOC and DOCG wines under Italian ministerial decrees. The designations—Denominazione di Origine Controllata and Denominazione di Origine Controllata e Garantita—identify wines governed by geographic-origin and production rules. The updated seals carry the Italian tricolor and a QR code intended to aid identification, traceability and security.¹

Older seals may remain in use until existing stocks are exhausted, so wines entering the United States during the transition can bear either version. TTB said this should have no practical effect on importers or consumers. The revised seal does not by itself require a new Certificate of Label Approval, or COLA; an existing approval remains valid unless another label change requires a fresh filing. Importers are still responsible for all other applicable labeling, import and regulatory obligations.¹

Office closure and compliance

TTB also announced that its offices would close on November 11 for Veterans Day. The newsletter directed industry members to resources covering which alcoholic beverages need formula approval, current processing times, and technical guidance for flavor ingredient data sheets and ingredient specification sheets.¹

Businesses that continue using FD&C Red No. 3 after January 15, 2027, or fail to obtain an approved revised formula when required, could encounter compliance problems involving production, labeling or importation. Meeting the deadline therefore requires both changing the ingredient and ensuring that each revised formula complies with FDA color-additive rules and the alcoholic-product standards administered by TTB.¹