Thanks John, you seem to have found what I was looking for. I see the Cider
(Hard) that I bought is 6% alcohol according to the label. I'll have to do some
more reading to see exactly whose jurisdiction it falls under, does seem to be
a grey area and strikes me as particularly dumb that all metric is required on
wine but no metric required on beer or malt beverages.
Mike Payne
----- Original Message -----
From: John M. Steele
To: U.S. Metric Association
Sent: Wednesday, 07 October 2009 17:05
Subject: [USMA:45947] Re: Hard Cider Labeling
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
