I just got a Pre-cola formula (beer) rejected on the basis of no hops in the formula. The TTB informed me that there must be at least 7.25lbs /100bbl, which isn't a heck of a lot, but its still a lot more than zero. I am a little stumped here. Is beer (majority of fermentables from malted barley) without hops considered wine? Anyone else have similar experiences or advice?
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TTB & un-hopped beer
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Yup, by tax law definition, hops must be used in the production of beer/malt beverages.
If it's an issue with you of not being able to get any hops at all, ask your hop supplier about "Treber" hops. I'll bet you can still get that, cheap.
If it's an issue of not wanting hop flavor/aroma/bitterness in your beer, then put the minimum required amount of hops in a cloth bag, dunk them in the kettle for a split-second, and be done with it. Treber hops are great for this also.
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When I contacted the TTB directly regarding producing a malted alcoholic beverage without hops (aka Gruit), I was informed by a Regulations and Rulings Division agent that I may brew any fermented beverage at a brewery with or without the addition of hops. However, if a fermented product does not contain hops, it does not meet the definition of malt beverage under the Federal Alcohol Administration Act (27 CFR 7.10). Therefore, TTB does not have the authority to issue a COLA for it. If you require a COLA for your product, the product must contain hops. You may request that TTB approve a formula that uses less than the 7 ½ pounds of hops per 100 barrels standard.
I'm wondering when I wouldn't require a COLA since I must have a label on any bottle I sell or a keg collar on any keg I sell. If I can produce a fermented beverage without hops and without a COLA and the TTB does not recognize it as beer, do I still have to pay excise tax on it!?!Glacier Brewing Company
406-883-2595
info@glacierbrewing.com
"who said what now?"
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The only circumstance I know in which you don't need a COLA is if you sell your beer within your state and your state doesn't require a COLA.
I do question this statement:
I was informed by a Regulations and Rulings Division agent that I may brew any fermented beverage at a brewery with or without the addition of hops.
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Originally posted by pennbrew2
If it's an issue of not wanting hop flavor/aroma/bitterness in your beer, then put the minimum required amount of hops in a cloth bag, dunk them in the kettle for a split-second, and be done with it. Treber hops are great for this also.Scott Metzger
Freetail Brewing Co.
San Antonio, TX
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Originally posted by pennbrew2The only circumstance I know in which you don't need a COLA is if you sell your beer within your state and your state doesn't require a COLA.
I do question this statement:
I believe our Brewer's Notice only gives us the authority to produce malt beverages, as defined.
It seems to be a quagmire. I was told by the same TTB agent (this is a direct quote):
"You may make a fermented product without hops on brewery premises. Your Brewers Notice issued by TTB allows for this type of production. State requirements are sometimes more restrictive. You should contact the State of Montana to discuss the issue in regard to your state-issued license."
Seems to me we're (the craft brewing community) heading into a very gray area with commercial unhopped malted beverages.
DaveGlacier Brewing Company
406-883-2595
info@glacierbrewing.com
"who said what now?"
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It's been a few years since using Treber hops but my recollection is Treber hops are essentially spent hops from hop processing. They come in pelletized form. I don't recall them having any alpha acid contribution worth considering and the liquid they were used in was dosed so heavily with other flavor additives that the flavor impact was too minimal for detection.
If you're still interested in Treber hops give HopUnion a call. They were the supplier we used at the time.
Hope this helps!Mike Jordan
Brewmaster
Boxing Cat Brewery
Shanghai, P.R. China
michael@boxingcatbrewery.com
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