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New TTB Absinthe/Thujone Regs

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Hi There! I'm prepping my first absinthe formula for submission, and came across the new Modernization rule published by the TTB, which says, in part::: "With regard to the laboratory testing requirement, TTB is removing the testing requirement for products made with wormwood, and will update published guidance to reflect this change. However, TTB intends to continue to offer the same type of thujone-testing that it has previously provided for the next year, and will assist industry members and outside laboratories to develop their own thujone-testing capabilities."

I talked to a self described "TTB worker bee" on the phone yesterday, who was under the impression that they have stopped doing lab testing for thujone themselves, but are still requiring beverages be "thujone-free"--- and haven't yet published that guidance they allude to above. So basically, it seems like they are putting the onus on distillers to find a way to make sure absinthes are below the FDA-mandated minimum thujone amount...

Does anyone have any experience with getting absinthe approved since this rule has passed? It makes me a little nervous, since beyond the fact we're a tiny operation and this sounds expensive, presumably they will now be enforcing this rule with product testing--- so even if/when we do figure out a way to test for this, there are enough variables in production (where the wormwood's coming from, time of year harvested etc etc) we could use identical production techniques and have one batch be below the level, and the next be above! So I guess I'm looking 1) to  commiserate about how this rule might actually make things more complicated, and 2) for any tips on moving forward, either with finding a lab who can do this kind of thing, or a way to test ourselves, or a way to ensure our production technique minimizes thujone levels!

Thanks, Nate

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There are other things like licorice that also must be below a minimum which the TTB does not test for and does not require you to test for.  You just need to provide them an explanation on how your formula meets the requirements.  I think the consensus here is that thujone doesn't make its way through the distillation process very well or even perhaps at all, so any proper distilled wormwood is going to be by definition be thujone "free".  Whether they would accept that written explanation I do not know, but I would try it before worrying too much about trying to test for it somehow.

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