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Limited ingredients clarification - thujone & safrole


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I note that the TTB Limited Ingredients list under Flavoring Substances and Adjuvants lists a number of additives where there are limits on specific chemicals. Specifically, I note that many items list they must be thujone free or safrole free. I was surprised, since I thought that the use of Wormwood for absinthe, for example, was allowed with a limited thujone content of 10mg/kg, I guess as effectively thujone free, but I can't find the reference for that. Specifically, I wonder if there is an equivalent reference for what constitutes safrole free, since I am interested in using sassafras leaves. Interestingly, the FDA specifically prohibits the inclusion of sassafras for the intended purpose of providing safrole or derivatives (they give the example of sassafras tea), but not for other purposes. I know that ground sassafras leaf is allowed by the FDA as file for gumbo thickening agent, but again can find no de minimus limit for safrole in that case either.

Update: I did find the TTB industry circular 2007-5 that indicates the 10mg/kg for thujone is based on the current recognized limit of detectability of the FDA approved analytical method. Hence, if they ever change the method to allow greater sensitivity, the limit would be reduced. Industry circular 61-2 prohibits use of safrole, oil of sassafras, etc., but has no de minimus and does not specifically prevent use of sassafras leaf, for example. The best info I found was Compliance Matters 94-2, where it indicates these plant materials can be used, but the result must be safrole free, again no indication of sensitivity limit as is done for thujole.

So, if anyone out there has gone forward to the extent of actually determining how the TTB handles the issue of safrole verus thujole, please let us know what you have learned.

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