From Kegs to Labels: What Federal Rules Mean for Local Brewers and Distillers

As craft brewing and small-batch distilling continue to grow across our broader community, federal regulators are reminding producers that even the smallest operations are held to the same labeling and compliance standards as national brands. Recent guidance from the Alcohol and Tobacco Tax and Trade Bureau highlights everything from how “non-alcoholic” and “alcohol-free” beverages must be labeled, to the importance of tracking alcohol content and securing label approvals before products ever reach consumers.

The updates also clarify that responsibility for label approval ultimately falls on the bottler—regardless of shared facilities or production arrangements—reinforcing a consistent standard across the industry. Taken together, the guidance underscores a simple reality for local brewers, wineries, and distillers: as experimentation and innovation expand, so too does the need for careful compliance behind the scenes to ensure products can be sold legally and accurately represented to customers.

One example comes from TTB investigators, who note that kegs are treated no differently than bottles or cans when it comes to labeling requirements. That means each keg must include key information such as alcohol content, product classification, and the federally required health warning—displayed in a compliant, legible format. Labels must also be firmly affixed, and common errors include missing information, unclear product designation, or improperly formatted warning statements. Even for smaller producers, taking the time to double-check keg labeling before distribution can prevent costly compliance issues down the line.

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For brewers experimenting with low- and no-alcohol options, labeling rules become even more specific:

Terms to Describe Low and No Alcohol Malt Beverages

Have you ever wondered what the difference is between a “non-alcoholic” and “alcohol free” malt beverage (i.e., beer made with both malted barley and hops)? How about “low alcohol” and “reduced alcohol”? Read on to find when these terms may be used to describe the alcohol content of low or no alcohol malt beverages. See 27 CFR 7.65(d)–(f).

• Low alcohol and reduced alcohol. The terms “low alcohol” or “reduced alcohol” may be used only on labels of malt beverages containing less than 2.5 percent alcohol by volume. The actual alcohol content may not equal or exceed 2.5 percent alcohol by volume, regardless of any tolerance permitted at 27 CFR 7.65(c).
• Non-alcoholic. The term “non-alcoholic” may be used on labels of malt beverages only if the statement “contains less than 0.5 percent (or .5%) alcohol by volume” appears immediately adjacent to it, in readily legible printing, and on a completely contrasting background. No tolerances are permitted for malt beverages labeled as “non-alcoholic” and containing less than 0.5 percent alcohol by volume.
• Alcohol free. The term “alcohol free” may be used only on malt beverages containing no alcohol. No tolerances are permitted for “alcohol free” malt beverages.

Malt beverages that meet the definitions above are subject to the formula and labeling requirements in 27 CFR part 25 and, if sold in interstate commerce, are subject to the labeling and other regulations in 27 CFR part 7. If you are interested in making any of these products, be sure to become familiar with the applicable requirements!