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CURRENT METHODOLOGY & REGULATORY
ENVIRONMENT
LAW <0 5% ABV
l h li
• : .
= non‐a co o c
• Commercial self‐testing done
regularly
via TTB “recognized” labs
• No specific methodology for kombucha, TTB recommends using beer methodologies
– Distillation/Densitometry ‐ IDs components based on light & density
– Gas Chromatography ‐ separates components based on vapor point
• TTB occasionally completes its own testing of kombucha off the shelf (densitometry)
– Non‐compliance: warning letter via mail sent to company
• Options: reformulate or register as an alcoholic beverage
• “Refrigeration cannot be used as a method to keep alcohol in compliance"
ISSUES/IMPLICATIONS WITH CURRENT ENVIRONMENT
• Very low degree of accuracy/precision observed with densitometry (+/‐1%)
• Very low degree of accuracy/precision observed with GC (using beer methodologies)
– Labs “tweak” the accepted methodologies for kombucha
– No singular way to test kombucha
•
Kombucha is unique
‐ not like beer or even NA beer at all!
– Acetic acid ferment (like vinegar)
– Plethora of organic & amino acids
– Low pH (typically 2.9‐3.5)
Impact accuracy
– Residual sugars
– Complex sediments
– Natural carbonation
• Refrigeration keeps many beverages from fermenting, beyond kombucha!
• Potential for NA beverage to be regulated/taxed as alcoholic when not warranted
• Impede commerce: Halt a growing industry from being able to expand
of methodology