In January 2025, the Alcohol and Tobacco Tax and Trade Bureau published two proposed rules that together would reshape every alcohol label in the United States. Notice 237 would require an "Alcohol Facts" statement — a standardized panel disclosing per-serving alcohol and nutrition information. Notice 238 would require disclosure of major food allergens used in production.

Comment periods closed in August 2025 after an extension, and the final rules are now pending. Once they publish, TTB has proposed a compliance date of five years out. Five years sounds generous — until you do the math on what a full relabel of your portfolio actually involves.

What the Alcohol Facts panel would require

Under Notice 237, every beer, wine, and spirits product under TTB's labeling authority would need an Alcohol Facts statement disclosing:

• Serving size and servings per container

• Alcohol content as percent alcohol by volume

• Fluid ounces of pure ethyl alcohol per serving

• Calories per serving

• Carbohydrates, fat, and protein in grams per serving

If that sounds like a Nutrition Facts panel, that's the point. Alcohol has been the one aisle of the store where the package tells you almost nothing; TTB is proposing to close that gap with a standardized, formatted panel — with all the type-size, placement, and formatting rules that come with one.

What the allergen rule would require

Under Notice 238, labels would need to declare the nine major food allergens — milk, eggs, fish, Crustacean shellfish, tree nuts, wheat, peanuts, soybeans, and sesame — whenever an ingredient containing protein from one of them is used in production, unless an exception applies.

This reaches further than most producers expect. Fining agents used in winemaking (egg whites, casein, isinglass), wheat in some vodkas and many beers, nut adjuncts in craft brewing — production inputs that never appeared on a label before would now trigger mandatory declarations.

Why five years is shorter than it sounds

When the final rules publish, every existing label in your portfolio becomes a rework project with a deadline:

• Design: The Alcohol Facts panel needs physical space on labels that were never designed to hold it. Small-format cans and spirits back labels are already tight; many will need a full redesign, not a patch.

• Data: Per-serving calories, carbohydrates, fat, and protein require lab analysis or validated calculation for every SKU — numbers most alcohol producers have never had to generate.

• Approval: A changed label generally means a new COLA. TTB already processes roughly 180,000 label applications a year with a correction-resubmission problem; the industry-wide relabel wave will hit that same queue. Brands that file early file against a short line. Brands that file in year four will be standing behind everyone else who waited.

• States: Label changes ripple into state brand registrations, many of which require re-filing when the label changes.

The brands that treat the final rule's publication date as the start of their project will spend the five years fighting for lab capacity, design cycles, and queue position. The brands that build their label data and compliance process now will treat it as a formatting exercise.

What to do before the final rules land

• Inventory your SKUs and label real estate now. Know which packages physically cannot absorb a new panel without redesign.

• Start collecting per-serving nutrition data. Calories, carbs, fat, and protein per serving for every product. This is the longest-lead item and it is useful regardless of the rule's final form.

• Map your allergen exposure. Audit production inputs — including fining and processing agents — against the nine major allergens.

• Get your current labels clean. A relabel wave is also a chance for TTB to catch pre-existing violations. Labels that already comply with the current rules (warning statement typography, class and type, mandatory information) will move through re-approval fastest.

Get your portfolio relabel-ready with Truli

Truli's compliance engine already checks alcohol labels against the current text of 27 CFR parts 4, 5, 7, and 16 — warning statement typography, class and type designation, mandatory information, and formatting — and we track TTB rulemaking as it moves, so Alcohol Facts and allergen checks ship the moment the final rules publish. Get your portfolio scanned and clean now, and the biggest relabel in alcohol history becomes a formatting update instead of a fire drill. Book a demo to see where your labels stand.