The history of beer is strewn with styles you’ve never heard of. We all know about pilsners, and IPAs, and stouts, and ambers. But what about wit, a fizzy yellow Dutch beer made with coriander and grains of paradise? Or gruit, a Northern European style brewed with pine, sweet gale, or mugwort? Or T’ej, an Ethiopian mead that Dogfish Head once blended with an imperial stout (see: Dogfish Head’s Bitches Brew).
All of these styles use ingredients that may not be Generally Recognized as Safe (“GRaS”). The Food and Drug Administration (“FDA”) maintains a list of ingredients that are GRaS. Beer and other alcoholic beverages may not use ingredients that are not GRaS. Although, if there is “widespread knowledge among the community of qualified experts” that the ingredient is safe, the ingredient need not actually be on the FDA’s GRaS list.
The GRaS list is not the same thing as the “Exempt Ingredients and Processes Determined to be
Traditional Under TTB Ruling 2015–1.” The Tobacco and Trade Bureau requires Recipe Approval for all alcohol beverages. There are lots of exceptions to the Recipe Approval process. For beer, the full list of ingredients (and processes) that can be used without getting Recipe Approval is found in Attachment 1 of Ruling 2015-1 (linked above). As a note, wines and distilled spirits have their own rules related to when Recipe Approval is required.
Thus, if the ingredient (of beer) isn’t in Ruling 2015-1, it merely requires Recipe Approval. But if the ingredient isn’t on the GRaS list, it can’t be used at all – even with Recipe Approval (in fact, your recipe won’t be approved).
On February 3rd, the TTB let us all know that Ethiopian Hops are not on the GRaS list.
The U.S. Food and Drug Administration has not evaluated the safety of “Ethiopian hops” for use in alcohol beverages, has not issued a regulation authorizing the use of “Ethiopian hops” in alcohol beverages, and is not aware of a GRAS (Generally Recognized as Safe) conclusion for the use of “Ethiopian hops” in alcohol beverages. Consequently, TTB will not approve an application for formula approval for an alcohol beverage containing “Ethiopian hops.”TTB FAQ’s Alcohol Labeling and Formula Division A.30-A32.
So, if you were thinking of using Ethiopian Hops in your authentic T’Ej … you shouldn’t do that.