饮料 RACC 与份量惯例
水和即饮饮料默认 240 mL / 8 fl oz 每份。浓缩液为 30 mL。能量饮有自己的规格。我们从 FDA 表格自动选定 RACC。
饮料专属 FOP 阈值
墨西哥的糖八边形对饮料在能量占比 ≥ 5% 时触发（固体为 10%）。智利的“ALTO EN AZÚCARES”在 5 g/100 mL 时触发。每个启用 FOP 的市场我们都套用饮料专属阶梯。
咖啡因与甜味剂披露
适用时触发阿根廷 Ley 27.642 的“CONTIENE CAFEÍNA”和“CONTIENE EDULCORANTES”矩形警示。厄瓜多尔、秘鲁和乌拉圭有类似披露。
多口味 SKU 管理
同一基液 10 种口味？保存基液，复制并调整风味香精，生成 10 张标签。配料声明按 SKU 自动调整。
If it contains juice, you owe a percentage declaration
A beverage that purports to contain juice - by name, by image, or by implication - has to declare its percentage juice content under 21 CFR § 101.30. This catches more products than people expect, because the trigger is what the package suggests rather than what the formula contains.
A sparkling water with a lime on the front and no juice in the bottle raises the question. A "berry" flavoured drink with two percent juice has to say two percent. The declaration sits near the top of the information panel, and it is a common finding in warning letters precisely because brands treat the fruit imagery as marketing rather than as a claim.
Is your energy drink a beverage or a supplement?
This is the single biggest fork in beverage labeling, and brands sometimes pick a side without realising they have.
A product marketed as a conventional beverage carries a Nutrition Facts panel under § 101.9, uses food additives that are permitted for that use, and cannot carry structure/function claims freely. A product marketed as a liquid dietary supplement carries a Supplement Facts panel under § 101.36, operates under DSHEA, and takes the structure/function disclaimer.
What decides it is not the format of the container. The FDA looks at how the product is represented - its name, its labeling, its marketing, the serving size, the packaging format, and whether it is positioned as something you drink for refreshment or take for an effect. A 16 oz can sold in the chiller next to soft drinks reads as a beverage no matter what the panel says.
Getting this wrong means the wrong panel, potentially the wrong permitted ingredients, and claims you are not entitled to make. It is worth deciding deliberately, early, and documenting the reasoning.
If there is alcohol in it, the FDA may not be your regulator
Most alcoholic beverage labeling falls to the TTB - the Alcohol and Tobacco Tax and Trade Bureau - under the Federal Alcohol Administration Act, not to the FDA. That covers distilled spirits, wine above the statutory threshold, and malt beverages made from malted barley and hops.
But the split is not clean, and the exceptions are exactly where the modern drinks market lives. Certain low-alcohol wines, ciders below the threshold, and beers brewed without malted barley or without hops can fall outside TTB's remit and back under the FDA - which means a Nutrition Facts panel and FDA ingredient labeling rather than TTB requirements.
Hard seltzers, sake-based products, and gluten-free beers made from sorghum or rice are the usual candidates for this confusion. If you are anywhere near that boundary, confirm which agency governs your product before you commission artwork, because the two regimes want genuinely different labels.