Water regulation question

[Nil]

I just went through the TTB website and review the new regulations regarding ingredients. They added a whole bunch of adjuncts that don't require formulation filing if used.

Yet, they don't say anything about water. The only time that the term "reverse osmosis" and "ion exchange' is used is relative tho beer and not wort or water. The text implies that if one is going to use eight RO and IE in BEER, then one will have to file for formula approval.

However, this process apply for water and NOT wort or beer.

Based on the text, I concluded that if one use RO or IE treated water to only dilute city water (i.e. to mitigate hard water), then formulation filing won't be required.

Any thoughts?

Thanks, Nil

 

[Talgrath]

Do you have a link to what you're talking about? I'm curious to have a look.

 

[Nil]

https://www.ttb.gov/beer/exempt-ingre.shtml

 

[Talgrath]

If I'm reading this right, this is referring to things done after the beer has been made, it is not referring to the water. The idea is to, I think, prevent beer brewers from then running the beer through processes to make hard alcohol and avoid paying taxes, which are usually higher on spirits. By requiring that they file the formula, someone can look at said formula and determine if they will be doing the equivalent of distillation and therefore apply the appropriate taxes. Generally speaking, I don't think these regulations are concerned with water at all.

 

[Nil]

I went through the text again. Water is included between the lines when they refer to "using any of the following non-traditional processes". Since beer is basically 95% water, they are referring to any kind of non-traditional ways to manage water as part of the process.

This also implies that, city water salt modification do no require to file a formula. For example, if I add calcium sulphate to augment bitterness, I don't need to file a formula. Salts are no mentioned in the text.

However, if RO water is used, then I would have to file the entire process, including salt modifications.

Any thoughts?

Thanks, Nil

 

[jddevinn]

TTB regulation 27 CFR 25.55 provides that a brewer must submit a formula for approval by TTB when the brewer intends to produce any fermented product that will be treated by any processing, filtration, or other method of manufacture that is not generally recognized as a traditional process

They are referring to treating beer (post fermentation) to a "non traditional" filter, with the list of examples being ways to concentrate alcohol.