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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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