Guide
Food labeling for US kombucha brands
Retail kombucha in the United States is labeled as a packaged beverage: identity, fluid ounces, ingredients (tea, sugar, culture, flavorings), any major allergens that actually went into the bottle, Nutrition Facts, and a business address. Alcohol, live-culture and “detox” claims sit beside that panel — they do not replace it.
Reviewed against official guidance.SourcesNot legal advice.
The short answer
Retail kombucha in the United States is labeled as a packaged beverage: identity, fluid ounces, ingredients (tea, sugar, culture, flavorings), any major allergens that actually went into the bottle, Nutrition Facts, and a business address. Alcohol, live-culture and “detox” claims sit beside that panel — they do not replace it.
Where this shows up in a real kitchen
Kombucha brands argue about ABV, SCOBY and “raw”. They forget ginger-lemon SKUs that pick up none of the nine majors, and “creamy” or milk-tea SKUs that pick up milk. A second-ferment fruit puree can add mango with no allergen, or a coconut-cream float that is coconut. Sugar used to feed the culture still shows up as added sugars if residual sugar remains.
The US rule
FDA packaged food (beverage) unless you have crossed into an alcoholic-beverage TTB lane. 21 CFR 101 for identity, net contents in fl oz, ingredients, Nutrition Facts. FALCPA only for majors present. Residual alcohol labeling and “non-alcoholic” claims have their own tests — keep the ABV honest. “Probiotic” and structure/function claims are extra scrutiny, not a substitute for 101.9.
How to apply it
Measure fill volume. List tea, sugar, culture, fruit. Declare milk or coconut if they are in a flavored SKU. Set Nutrition Facts from the bottled liquid, including residual sugars after ferment. Do not copy a ginger SKU’s empty Contains line onto a coconut cream SKU.
- Confirm you are still in FDA food, not TTB alcohol, for this batch’s ABV.
- Put identity and fluid ounces on the front.
- List ingredients from the tank sheet; declare majors only if present.
- Lock Nutrition Facts to residual sugar and the serving you actually sell.
Worked example
16 fl oz “Ginger lemon kombucha”: brewed tea, cane sugar, kombucha culture, ginger, lemon. No Contains line. Nutrition Facts for 8 fl oz (2 servings) or 16 fl oz if you treat the bottle as one serving. A “horchata cream” SKU that adds milk and cinnamon declares milk the day dairy enters the tank.
Checks that belong on this pack
| Check | Why it matters |
|---|---|
| ABV matches what you can defend | A “kombucha” identity does not hide alcohol. |
| Coconut cream SKU names coconut | Tea is not a tree nut; coconut is. |
| Added sugars reflect what is still in the bottle | Sugar fed to yeast is not automatically zero. |
| No leftover Contains: soy from a bottled-tea sister brand | Each SKU has its own majors. |
Putting “living cultures” on the front and ingredients only in a QR code
A culture story is marketing. Fluid ounces, ingredients and Nutrition Facts still belong on the bottle.
What LabelClear can and cannot print
Draft the tank ingredients and mark milk or coconut when those SKUs exist. Then add fl oz, residual-sugar Nutrition Facts and any alcohol statement — LabelClear does not print those FDA beverage panels.
Questions
Is kombucha cottage food?
Do I declare the SCOBY as an allergen?
Can I say “detox”?
Official sources
Everything on this page traces back to these. Where they and we disagree, they are right — tell us and we'll fix it.
- Food Labeling GuideU.S. Food and Drug Administration
- Nutrition labeling requirementsU.S. Food and Drug Administration
- Food allergiesU.S. Food and Drug Administration
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