
Cask-conditioned beer is naturally carbonated, unfiltered, unpasteurized, and uncentrifuged. These are the beers you see bar tenders laboriously hand-pumping to siphon the beer into your glass. “Real ale,” as some purists call it.
The TTB does not require a brewery to submit for approval any formulas for beer that is produced through traditional processes. Cask-conditioned beer (unless it uses some weird ingredients during brewing) does not need formula approval.
Non-traditional methods for which approval must be obtained, according to the TTB’s regulations, include: “removal of any volume of water from beer, filtration of beer to substantially change the color, flavor, or character, separation of beer into different components, reverse osmosis [(pre-mash reverse osmosis is standard and does not require approval)], concentration of beer, and ion exchange treatments.” Those all sound like non-traditional methods.
But, when did pasteurization, filtration, and forced carbonation become “traditional processes.” When does a standard industry practice become the norm, for which formula approval is no longer needed?
Ice beers, as we’ve mentioned, are in some circumstances considered by the TTB to be a traditional process. So, removal of some water from beer is now acceptable without formula approval. There is no definition of how much filtration will require formula approval, so, that standard could change as well depending on industry practice.
The TTB manufacturing regulations for the wine industry are much more specific (even specific Brix concentrations are stated and required). With the beer industry, however, interpretation of the regulations shifts with the policies of the agency.