Mark Solini is the vice president of government affairs at the Brewers Association of America. A beer enthusiast and homebrewer, he has been advising small, independent craft breweries on legal matters for over two decades. Mark holds a J.D. from Georgetown University Law School, and in his spare time, he homebrews beer with his adult children.
This article was originally published on December 6, 2024 and last updated on December 19, 2024.
On Thursday, December 5, the U.S. Alcohol and Tobacco Tax and Trade Bureau (TTB) issued Industry Notice 2024-2, exempting 24 brewing ingredients from the recipe submission and approval requirements. This notice is in response to two previous applications filed by the Brewers Association (BA)—one in 2021 and the other in 2023—both requesting additional exemptions from recipe requirements. The TTB had previously exempted over 50 brewing ingredients from recipe requirements based on BA applications.
In accordance with new industry guidelines, the Alcohol, Tobacco, and Firearms Administration (ATB) has added the following ingredients to the list of ingredients exempt from formulation requirements:
Brewers should be aware that even if a specific ingredient (such as fruits or nuts) is exempt from these requirements, this does not mean that extracts, essential oils, or syrups (i.e., flavorings) made from this ingredient are exempt from the recipe requirements. Going forward, the use of these ingredients will no longer require the submission and approval of a corresponding beer recipe to the Bureau of Alcohol, Tobacco, Firearms, and Explosives (TTB).
BA appreciates the Alcohol, Tobacco and Firearms Bureau’s continued commitment to simplifying regulations and looks forward to continuing to work with the agency to reduce the regulatory burden on industry and government resources.
Mark Solini is the vice president of government affairs at the Brewers Association of America. A beer enthusiast and homebrewer, he has been advising small, independent craft breweries on legal matters for over two decades. Mark holds a J.D. from Georgetown University Law School, and in his spare time, he homebrews beer with his adult children.
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Post time: Dec-16-2025