Lindsey Zahn P.C. advises cideries on TTB permits, state licenses, labels, formulas, and excise taxes, including ciders under 7% alcohol by volume that fall under FDA labeling rules. Cider sits between wine, beer, and FDA rules, and the firm works across all three.
The cider industry has grown dramatically. TTB has no cider-specific federal permit, but it has updated its policies and regulations on hard cider labels and excise taxes. With frequent changes and few clear rules, cider labeling is one of the hardest compliance tasks producers face, and it is not unusual for ciders to be labeled incorrectly even after receiving a COLA.
Lindsey Zahn P.C. helps new and established cideries choose the right permits, label correctly, and handle ciders under 7% alcohol by volume that fall under FDA rules.
How the Firm Helps
- Determine the right federal TTB permit for your business
- Draft and file the federal basic permit application with TTB
- Update and amend TTB permits
- Draft and file state license applications and amendments
- Draft and submit formulas for cider products that require them
- Review labels and represent you during the COLA process
- Develop labels for hard ciders under 7% alcohol by volume under FDA rules
- Provide ongoing compliance guidance
Process and Timeline
- Plan the right structure. The firm maps your products and sales plans to the federal permit and state licenses you need.
- Federal permit. The firm prepares and files the federal basic winery permit or brewer’s notice, depending on your cider with TTB.
- State licensing. The firm prepares the state license, including New York State Liquor Authority filings for New York businesses.
- Formulas and labels. Before launch, the firm handles formulas, label review, and COLAs so products can ship on time.
Federal and state applications can often be prepared in parallel. Plan for agency review on both before your opening or launch date, and file labels and formulas once your permits are on track.
Recent Representations
- Advised on FDA regulations for a hard cider under 7% alcohol by volume
- Counseled a cider company on non-apple and non-pear ingredients and their labeling and excise tax implications
- Drafted the federal basic permit for a new cidery
Prior results do not guarantee a similar outcome.
Frequently Asked Questions
Is there a TTB permit just for cideries?
No. TTB has not created a cider-specific permit, so cideries need to choose the permit that fits their operation. The firm can determine which applies.
Does the firm work with businesses outside New York?
Yes. TTB and FDA requirements apply nationwide, and the firm represents clients across the United States on federal matters. It handles New York State Liquor Authority filings directly and advises on other states’ rules as your distribution grows.