Brewers across the globe are starting to lean heavily into the trend of cannabis-inspired beer, paying homage to the plant by infusing terpenes that pay homage to the flavor, aroma, and effects of cannabis.
What many brewers may not know is that when using terpenes for beverage infusions, terpenes must be approved by the Alcohol and Tobacco Tax and Trade Bureau (TTB), but the TTB has strong restrictions on what kinds of terpenes will receive approval.
Here we break down the use of terpenes in beverages like beer, how to source TTB approved terpenes for beer, and what processes a brewer needs to undergo before bringing terpene-infused beer to the store shelves.
Terpenes at a Glance
Terpenes exist within the essential oils of all plants and are what are responsible for the way plants smell and taste, as well as some of the effects one experiences when ingesting cannabis. While thousands of terpenes have been identified within the plant kingdom, cannabis is said to have 120 different terpenes, expressed in different concentrations in various strains, or cultivars, of cannabis.
Terpenes make up the unique traits and characteristics of different cannabis strains or cultivars. For instance, cannabis strains heavy in the terpene limonene are known for their energizing effects, while cannabis strains with the terpene linalool are more known for bringing about calming, relaxation effects.
Brewing terpenes in beer involves choosing terpene profiles that will arouse a certain flavor while enhancing the beverage’s functionality through the effects brought on by terpenes. One example of a beer company using terpenes is Sweetwater Brewery, which partnered up with Cypress Hill to create Insane OG, a Mexican-inspired lager that also carries hints of the terpenes found in the popular cannabis strain OG Kush.
TTB Approval for Beer Products
All brewers know that they must receive approval from the Alcohol and Tobacco Tax and Trade Bureau (TTB) to bring beer products to market. The TTB is a government entity that ensures only qualified persons engage in the alcoholic beverage industry.
TTB approval is required for any beer product that contains spices, fruit, or any other food ingredient other than malt and hops. Receiving TTB approval on all formulations, including terpene-infused beer, is necessary for breweries to bring their products to shelves, although TTB does not oversee the sales aspect of alcohol.
Restrictions on Terpenes by the TTB
Most terpenes have been Generally Recognized as Safe (GRAS) by the Food and Drug Administration (FDA), and thus, many botanically-derived and synthetic terpenes can be used in beverages and approved by the TTB.
However, cannabis-inspired beer and alcoholic beverages that contain cannabis or hemp-derived terpenes will not be approved by the TTB.
As far as cannabis-derived terpenes go, they are considered part of the cannabis plant, thus remaining a Schedule 1 narcotic under the Controlled Substances Act (CSA). Even in states where cannabis is legal, cannabis-inspired beverages that contain THC, CBD, or terpenes are still deemed illegal under federal law and will not be approved by TTB.
The only circumstance under which anything derived from hemp would be approved by the TTB is if a product contains hemp seed oil, sterilized hemp seeds, and/or non-resinous, mature hemp stalks. In these cases, products must be clearly labeled that they do not contain controlled substances.
For brewers to integrate terpenes into their formulations, they must use terpenes that have been derived from botanical sources and have received TTB approval.
The Status of CBD and Beverages
Despite CBD becoming legal across the United States via The Farm Bill of 2018, the TTB has explicitly said that CBD does not belong in beer. At present, CBD ingredients have not been approved by the FDA, and with the TTB taking its lead from the FDA, they will not approve beverages containing CBD.
Until cannabis is federally legalized, states that sell alcoholic beverages containing THC, CBD, or cannabis-derived terpenes are doing so illegally.
On the other hand, companies creating non-alcoholic beverages containing terpenes are not subject to the same TTB requirements as those producing alcohol. However, certain regulations may govern the use of cannabis-derived terpenes.
Sourcing TTB Approved Terpenes
To be approved by the TTB, beverages containing terpenes must be formulated with TTB approved terpenes.
Companies that specialize in providing terpenes for cannabis-inspired beverage extract terpenes from botanical sources in their isolated form blend terpenes into various profiles. For instance, True Terpenes offers various terpene isolates, flavor blends, and customized formulations that help recreate the flavor profile of cannabis strains.
Terpene formulations are submitted to the TTB, and once a company is granted a submission account, they provide the TTB with details on every product seeking approval. These details include the various scientific names of the terpene, ingredients and formulation, and the source from which the terpene is derived (synthetic or natural).
Once the TTB has reviewed the formulations and has sought clarification on any questions, these formulations are granted TTB approval via a Flavor Ingredient Data Sheet (FIDS).
Breweries producing cannabis-inspired beverages or using terpenes to achieve certain flavor profiles can rely on companies like True Terpenes for sourcing terpenes that are TTB approved.
How to Receive TTB Approval for Terpene-Infused Beer
Brewers interested in producing and selling terpene-infused beer have to follow the TTB process as outlined.
They must first receive a Brewer’s Notice from the TTB, which authorizes a brewer to produce beer for sale. Once Brewer’s Notice is received, all formulations must be submitted to the TTB for approval. This is where the brewer will indicate that they have used TTB approved terpenes, purchased from a company like True Terpenes.
Once a formulation has been TTB approved, the brewer may produce terpene-infused beer products for sale.
Brew With TTB Approved Terpenes
True Terpenes offers a variety of TTB-approved terpene isolates, flavor blends, and customized formulations for brewers to take advantage of as the popularity of terpene-infused beer rises.
Our TTB terpene products are all Generally Recognized as Safe (GRAS), and are derived from the highest quality, food-grade, botanical sources.
Explore our shop, and be sure to learn more about Terpology®, a proprietary line of blends designed to produce effects based on expert research on terpenes and their interaction with the body.