TTB & un-hopped beer

[JoeV]

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?

[pennbrew2]

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.

[GlacierBrewing]

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!?!

[pennbrew2]

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.

I believe our Brewer's Notice only gives us the authority to produce malt beverages, as defined.

[Butcher Scott]

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.

In the current environment, this seems like a rather wasteful use of hops, but the best solution to making an unhopped beer. What methods would be best for doing this without wasting the hops? A quick dunk, then using for another batch made immediately afterwards?

[GlacierBrewing]

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 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.
Dave

[MikeJordan]

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!

[Moonlight]

If the TTB cannot figure out an intelligent way to address this, then I'll just dry-hop my grist with a hops in a mylar bag.