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    Columns

    Herbal Product Labeling: Alcohol Removed vs. Alcohol-Free

    Guidance policy recommends manufacturers of liquid herbal products clarify if products were manufactured using alcohol.

    Herbal Product Labeling: Alcohol Removed vs. Alcohol-Free
    Maged Sharaf, PhD, American Herbal Products Association (AHPA)09.08.16
    In its continued effort to ensure consumers are informed about issues that affect purchasing decisions, the American Herbal Products Association (AHPA) recently adopted a guidance policy to help consumers distinguish between products manufactured with alcohol that is then removed and products manufactured without any alcohol.

    AHPA’s recently adopted labeling guidance recommends manufacturers of liquid herbal products indicate if the product was manufactured using alcohol, and then the alcohol was removed. The recently adopted policy states:

    “AHPA recommends that manufacturers of liquid herbal products in which ethanol is used as a solvent and is subsequently removed refrain from using ‘alcohol-free’ on product labeling, unless the manufacturer establishes through appropriate testing that alcohol is not detected in the product. AHPA instead encourages the use of such terms as ‘alcohol-removed,’ ‘dealcoholized,’ or ‘nonalcoholic’ if the product contains less than 0.5 percent ethanol by volume. AHPA also encourages the inclusion of the phrase ‘contains less than 0.5 percent alcohol by volume’ or a significantly similar phrase.”

    The difference between products manufactured without using any alcohol and alcohol-removed products is very significant for certain consumers. AHPA’s alcohol labeling guidance provides more specific information for consumers that follow strict practices when it comes to avoiding the consumption of alcohol or products made using alcohol.

    U.S. Federal law defines a product with a 0.5 percent or more ethanol by volume as an alcoholic beverage [27 U.S. Code § 214(1).]. The U.S. Food and Drug Administration (FDA) does not consider the terms “non-alcoholic” and “alcohol-free” to be synonymous when applied to wine and malt beverages. The FDA takes the position that the term “alcohol-free” may be used only when such products contain no detectable alcohol. FDA considers such products containing less than 0.5 percent alcohol by volume as “non-alcoholic.”

    AHPA develops guidance policies to promote responsible commerce in herbal supplements. These policies address a variety of labeling and manufacturing issues and reflect the consensus of AHPA’s members and its board of trustees. 


    Maged Sharaf, PhD
    American Herbal Products Association (AHPA)

    Maged Sharaf, PhD, is the chief science officer of the American Herbal Products Association (AHPA), the national trade association with a focus primarily on herbs and herbal products. AHPA’s membership represents U.S. and international growers, processors, manufacturers, marketers and institutes specializing in botanicals and herbal products. Before AHPA, Dr. Sharaf was the director, Foods, Dietary Supplements and Herbal Medicines at the United States Pharmacopeial Convention (USP). Before USP he was pharmacy associate professor and has preceding experience conducting bioanalytical assay development and validation, and human bioequivalence studies in support of the pharmaceutical industry; and quality control and manufacturing of pharmaceutical dosage forms. He can be reached at 301-588-1171; E-mail: msharaf@ahpa.org; Website: www.ahpa.org.
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