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Brewery & Distillery
                                                                                                      Craft Brewery
               remaining healthy and avoiding unpleasant physi-
               cal symptoms. Brands getting into the gluten-free
               market need to understand that consumers with a
               medically prescribed diet will have more demands
               than the average consumer, and thus companies
               also need to go the extra mile to be transparent
               about their processes. You can reassure consumers
               by demonstrating you understand legal require-
               ments for labeling gluten-free products, partic-
               ularly recent rule changes by the Food and Drug
               Administration (FDA) and the Alcohol and Tobacco
               Tax and Trade Bureau (TTB).

                 In 2020, the FDA responded to growing awareness
               that ELISA tests used to identify gluten proteins in
               foods and beverages don’t reliably detect residual
               gluten in fermented products. To address the issue,
               the FDA passed a new rule that requires manufac-
               turers to start with gluten-free ingredients if they
               want to label products as gluten-free. At the same
               time, the FDA ruled that distilled products made
               from grains containing gluten could be labeled as
               gluten-free because distillation removes gluten pro-
               teins from the finished product. Following the lead
               of the FDA, the TTB released a ruling that allows
               makers of distilled beverages to advertise and label
               those products as gluten-free—even if they are
               made with grains that contain gluten.

                        Fermentation vs. Distillation
                              What’s Involved?

                 To understand the rationale behind the FDA and
               TTB rulings, makers of craft beers and spirits need
               to be aware of the differences between fermenta-
               tion and distillation. Typically, production of alco-
               holic beverages starts with fermentation. The fer-
               mentation process converts sugars into ethyl alco-
               hol by breaking down substances like grain or pota-
               toes through the introduction of yeasts, bacteria or
               other microorganisms. Beer usually starts with the
               fermentation of wheat or barley, two gluten-con-
               taining grains. Distilled spirits like whisky start with
               wheat or rye, while vodka can also be made with
               sugar cane or potatoes. Fermentation processes
               may break down some of the gluten proteins in
               beer or spirits, but it won’t remove all of them.

                 Distillation involves the boiling and condensation
               of fermented products to separate particulates in a
               liquid. During the distillation process, fermented liq-
               uid is heated up in a still. Under high temperatures,
               the most volatile compounds like alcohol become

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