A person who can consume dairy without side effects uses an enzyme called lactase to break down lactose, the sugar found in most dairy products.
My body produces almost zero lactase.
For the most part, the solution to this problem is just to avoid dairy. Other times, I knowingly consume dairy with the aid of a chewable pill that provides a short-term dose of the lactase enzyme my body lacks.
Of course, the key word there is “knowingly.” To prepare for lactose, I need to know I’m consuming it.
For food, it’s not too hard to figure out – grocery products are clearly labeled, and a quick question to a server clears up most ambiguities while dining out.
For beer, it’s another thing entirely. Brewers are now adding lactose sugars to every type of beer, from traditional styles like milk stouts to less common varieties like kettle sours and IPAs.
At a recent beer festival, I couldn’t take two steps without bumping into lactose.
Recently – and not for the first time—I consumed lactose in a beer where I never would have expected to find it (a session IPA). More importantly, the label gave no indication whatsoever that lactose was a significant ingredient. I discovered it only after feeling some discomfort and looking up details on the brewery’s web site.
But the real problem comes when these beers aren’t labeled. You want to create a Marshmallow Popsicle Cinnamon Toast Crunch Sour Stout? Go for it – just let me know what’s actually in that thing, and it’s on me to decide whether I want to put it in my body or (much more likely) stay far far away.
What’s in my beer?
This latest situation got me thinking about the significance of the issue. For me, the worst that can happen is a daylong stomachache.
But what about people with more severe allergies to ingredients like milk, wheat, and nuts, all of which find their way into beer more and more often? If we’re going to demand that brewers date code their beers (and we should), why not call for labeling potentially dangerous ingredients as well? And yes, I know alcohol is a dangerous ingredient.
So, with all of that lead up, what do brewers actually have to put on their labels?
Ask the TTB
In the U.S., there’s some state-to-state variation, but national requirements for labeling come from the Alcohol and Tobacco Tax and Trade Bureau (TTB). This group publishes the Beverage Alcohol Manual for Malt Beverages, which lists the information that must appear on beer labels.
It contains all the standards, from what must be on the packaging to legibility requirements and type size. If you’re interested in the finer details, you can check out that manual and a bunch of supporting material on the TTB’s Beer Labeling site.
For those of you who prefer the key points, here they are. Again, note that these are only U.S. federal requirements. Your state (or country) might differ.
This information must be on the front of the label:
- Brand name
- Class designation — the requirements give a lot of leeway here. A class can be as generic as “malt beverage” or as specific as “cream stout” or “wurtzburger,” the latter of which I’ve never even heard of.
This information must appear somewhere on the label:
- Name and address of producer, packager or importer
- Net contents — how much liquid is in the package. The label must use an American unit of measurement, though it can also use a second form, presumably metric. There are no federal standards for how much liquid is actually in the package; brewers just need to tell the consumer what it is.
- Health warning statement— the boilerplate paragraph about alcohol being dangerous.
- Country of origin (if not US)
Here’s where I would hope to see allergens – breweries have to put these ingredients on their label if it’s in the beer:
- Yellow #5
- Cochineal extract or “carmine”—a color additive
I’ve omitted a lot of other requirements that aren’t immediately relevant to the topic at hand, but I found one in particular pretty funny. Among the claims that you cannot put on a label are, explicitly stated, this exact wording: “pre-war strength” or “full oldtime alcoholic strength.”
The federal requirements state that these notable aspects are not required on the label:
- ABV—this surprised the heck out of me, though in hindsight I can recall some packages that don’t list it (Uinta and Lagunitas cans come to mind). Federal standards mark it as optional, noting that some state laws require it and others prohibit it. Why the hell would you prohibit it?
And actually, a separate clause (7.26) revised in 1993 explicitly states, “The alcoholic content and the percentage and quantity of the original extract shall not be stated unless required by State law.” What kind of crazy shit is that?!
Exception: You do have to list ABV for “malt beverages that contain any alcohol derived from added flavors or other added nonbeverage ingredients (other than hops extract) containing alcohol.”
- Major food allergens—Section 7.22a of the Labeling Requirements for Malt Beverages is titled “Voluntary disclosure of major food allergens” and notes that labeling is “on a voluntary basis.” The only meaningful requirement is that if a brewery discloses one major food allergen that’s in the beer, they have to disclose all of them. (I guess to avoid implying that an allergen is not in a beer.)
Okay, but do it anyway
The requirements are what they are, but this doesn’t seem like it should be a controversial issue. Putting allergens in beer without labeling does a major disservice to customers, is antithetical to the inclusive spirit that most craft breweries cultivate, and runs counter to good business practices.
Why would you want to make some of your customers sick? Or give them a bad impression of your beer?
At a recent beer share, I brought this up with a fellow guest, explaining why I wasn’t taking samples of unfamiliar beers without looking them up first. This guest turned out to be a local brewer whose brewery didn’t put allergy warnings on their menu. He admitted that he’d just never thought about it before but immediately recognized the sense of proper labeling.
“I’ll talk to the servers about changing our menu right away,” he said.
It can be as simple as that. Provide consumers with the information they need to make educated decisions. If there’s room for the upside-down beer bottle, there’s room for lactose.
- Craft Beer Is Losing Its Identity - 08/13/2019
- You Gotta Let Me Know: What Must (and should be) on the Beer Label - 01/03/2019
- Who am I drinking? A diagram of US beer ownership – Updated - 07/14/2018