Non-alcoholic beer labeling in the United States

Abstract

Alcohol product labeling is evolving [1]. In the United States, the Alcohol and Tobacco Tax and Trade Bureau (TTB) regulates alcohol labeling (among other aspects of production and distribution). The TTB currently has a proposal under review that would require labels of wines, distilled spirits and malt beverages to include an alcohol facts statement with information on alcohol content (percentage and terminology) and nutritional content (calories, carbohydrates, protein and fat) per serving [2].

Non-alcoholic beers can have an alcohol by volume content at just under 0.5%, while the term ‘alcohol-free’ is reserved for those at 0.0% [3]. A growing product category [4], market research suggests that consumers may not distinguish the non-alcoholic and alcohol-free labels [5]. In 2023, the World Health Organization called for updated labeling mandates to inform consumers, especially those seeking to completely abstain from alcohol [6]. If the TTB proposal is approved, non-alcoholic beers 1 would be required to report alcohol content, either through alcohol percentage and/or through specific terminology. If ‘non-alcoholic’ is used, then alcohol percentage would also be required. If ‘alcohol-free’ applies, then a percentage would not be required. Given the documented confusion regarding terminology, including both alcohol percentage and relevant terminology in the label would be most informative.

Regarding nutritional content, the Food and Drug Administration requires that soft drinks (e.g. sodas, juices) include nutritional content on their labels and, if the TTB proposal is approved, full-strength alcohol would follow suit. Under consideration is whether non-alcoholic beers will similarly need to report nutritional content. Similar to sodas and juices, non-alcoholic beer has calories and is typically nutritionally low. If product labels aim to inform consumers, nutritional content would be important to include on non-alcoholic beers, with potential to shape purchasing and health behavior [7].

Worth comment, yet absent from the TTB proposal, is labeling that warns against use in potentially vulnerable groups. Because the fermentation process can yield up to 0.5% alcohol by volume, certain kombucha companies voluntarily include on their label a warning against consumption for people avoiding alcohol (e.g. due to pregnancy, sensitivities). A similar warning on non-alcoholic beers may be worthwhile. While non-alcoholic beers can be a helpful substitute for some [8], their alcohol cues may activate craving for full-strength alcohol [9]. Additionally, as state and federal age-restrictions on non-alcoholic beers evolve [10], worth considering is labeling about the appropriateness for consumption by youth [11, 12].

At present, non-alcoholic beer labeling is largely self-regulated. Amidst growing public awareness of alcohol-related health risks [13], marketing strategies that position non-alcoholic beers as healthy alternatives to alcohol [14], and even some governments increasing non-alcoholic beverage availability as a public health strategy [15], greater attention to non-alcoholic beer regulations is needed. The TTB proposal, open for public comment until 15 August 2025, offers opportunity for contributing informed opinions on labeling of non-alcoholic beers with potential for individual and population health impact. We encourage public engagement from the expert readership of this journal, and in particular, call attention to aspects of the proposal regarding non-alcoholic beers.

This publication was made possible by NIAAA-funded K99 award (1K99AA031716) to M.A.B. Outside of this research, M.A.B. has consulted for a technology company aimed at helping people to reduce their alcohol use. The authors have no other interests to declare.