Some Googling shows that hard cider <7% ABV is exempt fro metric fill requirements. http://www.ttb.gov/pdf/notices_alcohol/notice881.pdf quoted snippet: We note there is some confusion in the industry on whether the wine labeling rules and standards of fill in 27 CFR part 4 apply to hard cider less than 7 percent alcohol by volume. They do not. The rules in part 4 implement the FAA Act, and apply only to wine which contains ``not less than 7 percent and not more than 24 percent of alcohol by volume.'' That is why hard cider under 7% alcohol by volume is exempt from ATF's label approval requirements and metric standards of fill. Instead, wine under 7 percent alcohol is subject to Food and Drug Administration labeling rules. However, ATF has some wine labeling jurisdiction under the IRC, which applies to all beverage wine containing 0.5 percent or more alcohol by volume. The IRC wine labeling rules are in 27 CFR part 24. These rules do apply to hard cider under 7 percent alcohol by volume. However, if FDA rules apply, it is not clear to me why dual labeling isn't required. It seems as though it should be. (or the product has totally fallen in a crack between agencies.)
--- On Wed, 10/7/09, Michael Payne <[email protected]> wrote: From: Michael Payne <[email protected]> Subject: [USMA:45943] Hard Cider Labeling To: "U.S. Metric Association" <[email protected]> Date: Wednesday, October 7, 2009, 10:24 AM Saw a bottle of Hard Cider yesterday day labeled as "22 ounces", I'm sure really means fluid ounces. No other quantity provided. It got me wondering what the law states here in the US on labeling hard Cider. In the US Cider is apple juice, Hard cider has an alcohol content. According to the Alcohol and Tobacco Tax and Trade Bureau (what a mouthful) http://www.ttb.gov/ Hard Cider is apple wine: *Hard Cider* Still wine derived primarily from apples or apple concentrate and water (apple juice, or the equivalent amount of concentrate reconstituted to the original brix of the juice prior to concentration, must represent more than 50 percent of the volume of the finished product) containing no other fruit product nor any artificial product which imparts a fruit flavor other than apple; containing at least one-half of one percent (0.5%) and less than seven percent alcohol by volume; having the taste, aroma, and characteristics generally attributed to hard cider; and sold or offered for sale as hard cider. *High-proof concentrate* For wine: A volatile fruit-flavor concentrate (essence) that has an alcohol content of more than 24 percent by volume and is unfit for beverage use (nonpotable) because of its natural constituents, i.e., without the addition of other substances. http://www.ttb.gov/forms_tutorials/glossary/letter_h.html http://www.ttb.gov/forms/f512036worksheet.pdf This leads me to wonder if the bottle is required to be labeled like wine with milliliters only. Anyone have any other information or input. I'm thinking of writing to the bottler in Michigan, who stated in an email that it's about 660 mL, "a common size for Cider in the US". Mike Payne
