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TTB Response to P&Fnow Vanilla Comments

Posted: February 6, 2008

In the December 12 edition of P&Fnow, Rick Brownell discussed his impressions regarding the Alcohol and Tobacco Tax and Trade Bureau's policy on vanilla:

Perhaps the most controversial presentation of the first day was given by Edward Limowski of the Alcohol Tax and Trade Bureau (TTB). The TTB is a branch of the US government, which regulates the use of alcohol in both alcoholic beverages and other non-beverage applications, including flavorings. Limowski spoke on proposed rule changes by the TTB and their potential impact on the vanilla industry. Limowski explained that the US Food and Drug Administration recently recognized Rhovanil (Rhodia) as vanillin derived from a natural process. The TTB is proposing several new categories of vanilla flavoring, which would all be recognized as natural, notably “Natural Vanilla Flavor Type,” which would not require any of the flavor to be derived from the named source, vanilla beans. Several attendees questioned not only the logic of the proposed changes, but also whether TTB has the authority to essentially rewrite the Federal Standard of Identity for vanilla.

Janet Scalese, chief of the nonbeverage products laboratory for the TTB, took a different view and submitted the following comments:

Based upon his summary of the Vanilla 2007 meeting in the December 12th issue of [P&Fnow], it is apparent that Mr. Rick Brownell of the vanilla extract manufacturer Virginia Dare misunderstood what was presented during one part of the symposium. His summation of the presentation given by Mr. Edward Limowski from the Alcohol and Tobacco Tax and Trade Bureau entitled TTB’s Proposed Regulatory Change and Its Effect on the Vanilla Industry contains an assessment of regulatory matters that could confuse members of the flavor industry. Mr. Limowski’s presentation included information about a material called Rhovanil produced by Rhodia. The U.S. Food and Drug Administration (FDA) determined that this material is vanillin produced by a natural process and is therefore a natural material. During his presentation Mr. Limowski explained that any formulas containing Rhovanil that are submitted to TTB can be considered natural flavors. He also provided examples of names of products to make sure that attendees understood that products using Rhovanil cannot be called vanilla flavors. Mr. Brownell apparently misunderstood Mr. Limowski’s presentation and concluded that TTB was proposing new standards of identity for vanilla products. That is not within TTB’s jurisdiction nor was it ever suggested by Mr. Limowski.

The FDA determines whether processes and chemicals are natural and TTB enforces that determination when materials are used in alcohol-containing flavors. If Mr. Brownell's confusion regarding this issue remains it can be clarified by addressing his concerns with the FDA concerning its determination regarding Rhovanil. If there is a potential for confusion on the part of customers purchasing material using Rhovanil, the flavor industry as a whole must properly educate those customers about such products.