Based on feedback we have heard from several ADI members, it seems the Food and Drug Administration is taking a more active role in the distilled spirits industry – heretofore primarily the domain of the TTB. This includes facility site visits and product integrity. With this in mind, it may be time well spent to review the FDA site regarding Ingredients, packaging and labeling, as well as Good Manufacturing Practices (GMPs) for the food industry. Keep in mind that “food” denotes anything consumable that you sell, including gift shop items like sauces, etc…
A recently announced recall at a major distillery is both cautionary and instructive. See this Spring press release from the FDA:
Recall — Firm Press Release
FOR IMMEDIATE RELEASE (March 2013) The Gift Shop at XXXX Distillery today voluntarily recalled all non-expired products listed below due to mislabeling and undeclared allergens. People who have an allergy or severe sensitivity to wheat, soy, anchovy, and/or milk, run the risk of serious or life-threatening allergic reaction if they consume these products.
All labels on future products will be corrected to list all allergens. The mislabeled products, all sold under the XXXX Distillery brand name, can be identified with the following names and are missing these allergens in the ingredients:
| PRODUCT | ALLERGEN | PACKAGE | UPC | BEST BY DATES |
| Bourbon Flavored Caramel Sauce | Milk and Soy | 8 oz jar | 2/16/14 | |
| Bourbon Flavored Fudge Sauce | Milk and Soy | 8 oz jar | 1/30/14 | |
| Marinade for Meat | Wheat, Soy and Anchovy | 12 fl oz bottle | 10/30/14 | |
| Barbecue Sauce | Soy and Anchovy | 16 fl oz jar | 1/19/15 | |
| Hot Barbecue Sauce | Soy and Anchovy | 16 fl oz jar | 11/7/14 |
