Ask The Brewmasters

Does anyone have any current references for the TTB definition of what an FMB is (required malt and hops)?  I found a really good paper in the TQ from 2007 written by Ray Klimovitz, which matches the ratios of malt and hops that I could find on the TTB website, however I have heard from other brewers that they use considerably less malt in their FMBs now than what was required back in 2007.  I haven't been able to find any written information to indicate that the minimum requirements for malt have changed.

The definition I found from the TTB website and the TQ article both say that 51% of the alcohol in the final beverage (when 6% abv or less) has to be made from a Malt beverage, which is made of a minimum of 25% malt (by dry weight) and 7 lb of hops per 100 bbl.  If anyone can point me to a TTB ruling or interpretation that shows a lower malt or hop requirement, I would appreciate it.

Thank you,

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Benjamin Bailey
Troegs Brewing Co
Hershey PA
(717) 534-1297X106
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Hi,

 I think this is what you're looking for. https://www.ttb.gov/images/pdfs/rulings/2008-3.pdf

"Section 117(a)(7) of the FAA Act (27 U.S.C. 211(a)(7)) defines the term "malt

beverage" as "a beverage made by the alcoholic fermentation of an infusion or

decoction, or combination of both, in potable brewing water, of malted barley with hops,

or their parts, or their products, and with or without other malted cereals, and with or

without the addition of unmalted or prepared cereals, other carbohydrates or products

prepared therefrom, and with or without the addition of carbon dioxide, and with or  

without other wholesome products suitable for human food consumption." The same

definition appears in the TTB regulations at 27 CFR 7.10."

 The ruling goes on into more detail about beer vs malt beverages, malt substitutes, the various definitions of beer, and heavily cites CFR, so it should have everything you need. 

 Let me know if you have any other questions, and, unlike a lot of federal agencies, TTB is also very helpful if you just give them a call. 

Cheers,

Kevin

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Kevin McCabe, PhD
Founder
Double Strand Consulting
kevin@doublestrandconsulting.com
https://www.doublestrandconsulting.com/
ASBC Alternative Beverage Subcommittee Chair
ASBC Technical Committee
MBAA Webinar Committee Chair
TTB Certified Chemist
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Original Message:
Sent: 06-07-2023 10:17
From: Benjamin Bailey
Subject: FMB Formulation

Does anyone have any current references for the TTB definition of what an FMB is (required malt and hops)?  I found a really good paper in the TQ from 2007 written by Ray Klimovitz, which matches the ratios of malt and hops that I could find on the TTB website, however I have heard from other brewers that they use considerably less malt in their FMBs now than what was required back in 2007.  I haven't been able to find any written information to indicate that the minimum requirements for malt have changed.

The definition I found from the TTB website and the TQ article both say that 51% of the alcohol in the final beverage (when 6% abv or less) has to be made from a Malt beverage, which is made of a minimum of 25% malt (by dry weight) and 7 lb of hops per 100 bbl.  If anyone can point me to a TTB ruling or interpretation that shows a lower malt or hop requirement, I would appreciate it.

Thank you,

------------------------------
Benjamin Bailey
Troegs Brewing Co
Hershey PA
(717) 534-1297X106
------------------------------