Using the word ‘clean’ on a beer label and alcohol advertising

How can you use the word clean on a beer label? In the latest Industry Note from the Alcohol and Tobacco Tax and Trade Bureau (TBB), the regulatory group explained how to use (and how not to use) the word “clean” in alcohol beverage labeling and advertising according to the Federal Alcohol Administration Act (FAA Act). The clarity is needed because inquiries about “clean” keep coming in.

Can I use the word clean on a beer label?

Turns out, TTB regulations “do not define the word clean, and we do not have standards for the use of the term on labels or in advertisements.”

But … “Consumers should not interpret the term as meaning that the beverage is organic or has met other production standards set by TTB. Instead, we review both labels and advertisements in their totality to determine if they create a misleading impression.”

How to use clean

In some cases, using the term clean on a beer label is simply used as a descriptor of the taste of a beverage, TTB “considers it puffery.” For example, “X winery makes a clean, crisp wine.”

In other cases, the word clean is used together with other language to create the misleading impression that consumption of the alcohol beverage will have health benefits, or that the health risks otherwise associated with alcohol consumption will be mitigated. For example, “X malt beverage is clean and healthy” or “Y vodka’s clean production methods mean no headaches for you.”

“We would consider the use of the term clean in these examples to be misleading health-related statements, which are prohibited under the FAA Act,” the TTB note states.

Head here for more alcohol beverage advertising and labeling guidance.