Tequila 100% agave - all kinds

Is tequila with 100% agave kosher for Passover?
Blanco, Reposado, Anejo?
Made in Mexico.

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is it no longer safe to assume 100% agave is kosher/for passover anymore?

Correct. Each brand needs investigation.

What questions should be asked to the company? I thought that the law in USA is that tequilla means 100% agave

If all that is in Tequila is Agave, how are there different flavors. They add different ingredients

Can’t we ask this of all items? Wouldn’t it be batel beshishim as any additive needs to be less than 1% similar to why it is permissible to drink whiskey (not pesach) that may have been aged in a barrel used for wine (correct me if i’m wrong here)?

I’m not sure I understand your question. The issue here is most tequilas say 100% Agave. However that doesn’t mean there aren’t other ingredients.
In reference to the wine in the barrels, those situations are ok becuz wine nowadays (Yayin Stam) is batel one in six.

I can’t speak for @Jacks721 but I am confused because my understanding of the law is that if it says 100% agave, it means 100% agave

5.1.1 “100% agave”
Pursuant to Section 4.34 of this NOM, a product whose fermentation may not be enhanced with sugars other than those obtained from the tequilana weber blue variety Agave grown in the territory specified in the Declaration. For the product to be considered “100% agave” Tequila, it must be bottled in the bottling plant controlled by the Authorized Producer, which must be located within the territory specified in the Declaration.

This product must be labeled using one of the following statements: “100% de agave,” “100% puro de agave,” “100% agave,” or “100% puro agave,” to which the word “azul” [“blue”] may be added.

Please provide link to this.

Is this from the FDA?

The CRT (El Consejo Regulador del Tequila, or the Tequila Regulatory Council) permits 1% of any 100% agave spirit to consist of additives without any change to the bottle’s label. Four types of additives are permitted: glycerin, caramel coloring, oak extract, and jarabe or sugar-based syrup.

The little research I did today claims that according to the CRT 100% Agave cannot even have 1% additives. However, it seems like the industry does not necessarily follow the CRT’s rules to the fullest extent and nor does CRT enforce all their own rules.

As such, at the moment, I dont see how we can rely on this to automatically approve all 100% Agave on the basis of the CRT alone.

This needs further research.


Key Points

  • The Tequila Regulatory Council (CRT) is a Mexican organization that oversees tequila production and labeling, ensuring compliance with official standards.
  • It seems likely that companies must follow CRT rules to produce tequila, with non-compliance potentially leading to fines or loss of authorization.
  • Research suggests that, officially, 100% agave tequila should not contain additives, but there is controversy over small amounts, especially in aged tequilas, with some sources claiming up to 1% additives are allowed without label changes.
  • The CRT’s jurisdiction covers the entire production process, from agave cultivation to marketing, and applies to designated regions like Jalisco.

What is the Tequila Regulatory Council?

The CRT, founded in 1994, is a non-profit organization that unites all tequila industry stakeholders, including agave producers and bottlers, to ensure tequila meets quality and authenticity standards. It certifies compliance with the Official Mexican Standard (NOM) and protects tequila’s appellation of origin globally.

Jurisdiction and Compliance

The CRT oversees the entire tequila production process, enforcing rules on geographical origin (e.g., Jalisco) and production methods. Companies must obtain CRT certification to produce tequila, and failure to comply can result in fines, inspections, or loss of the right to use the “tequila” designation, impacting their market viability.

Additives in 100% Agave Tequila

The claim that the CRT allows up to 1% additives (like glycerin, caramel coloring, oak extract, and sugar syrup) in 100% agave tequila without label changes is likely false based on official regulations, which state no additives should alter its nature. However, there’s debate, with some sources suggesting small amounts are tolerated, especially in aged tequilas, highlighting industry transparency issues.

Unexpected Detail: Industry Debate

While official rules ban additives in 100% agave tequila, some producers may use them in small quantities, leading to initiatives like the Additive-Free Alliance, which the CRT has criticized, adding complexity to consumer choices.


Survey Note: Comprehensive Analysis of the Tequila Regulatory Council and Additives

The Tequila Regulatory Council (CRT), established on May 17, 1994, is a pivotal non-profit civil organization in Mexico that brings together all actors in the tequila production chain, including agave producers, distillers, bottlers, distributors, and government entities. Its primary role is to inspect, analyze, and certify compliance with the Official Mexican Standard (NOM) for tequila, as outlined in NOM-006-SCFI-2012 (Tequila.net: What are the regulations governing Tequila?). This ensures the authenticity and quality of tequila, safeguarding its appellation of origin both in Mexico and internationally, as detailed on the CRT’s official website (CRT Website). The CRT’s efforts are crucial for maintaining consumer trust, verifying that tequila is produced in designated regions like Jalisco, Guanajuato, Michoacan, Nayarit, and Tamaulipas, and using exclusively Agave tequilana weber, blue variety, for 100% agave tequila.

Jurisdiction and Scope

The CRT’s jurisdiction extends across the entire tequila production process, from agave cultivation to marketing. This includes specifying the geographical areas where tequila can be produced, the types of agave permitted, and the distillation methods, as noted in regulatory guides like Diffords Guide: Tequila’s Appellation and Regulatory Bodies. The NOM-006-SCFI-2012 sets standards for production, bottling, and labeling, ensuring tequila meets quality benchmarks. For instance, all 100% agave tequilas must be bottled in Mexico, while mixto tequilas (containing at least 51% agave) can be bottled outside the country in bulk, as explained in Casa Agave: Tequila Regulations. This distinction is critical for understanding the CRT’s regulatory reach and its impact on global trade.

Mandatory Compliance and Consequences

Companies wishing to produce, bottle, or market tequila must obtain CRT certification, which requires full compliance with NOM regulations. This involves documentary approval for all aspects, such as product, bottle, and label, with the CRT certifying producers under ISO 9002 standards since 1999, as mentioned in Aceves Spirits: Mexican Regulations On Establishing A New Tequila Brand. Non-compliance can lead to severe consequences, including fines, additional inspections, or, in extreme cases, revocation of the authorization to use the “tequila” designation, severely affecting commercial viability. Enforcement is handled by the Ministry of Economy and the Federal Consumer Protection Agency (PROFECO), with the CRT conducting inspections to verify adherence, as noted in Tequila.net: What are the regulations governing Tequila?. This underscores the CRT’s role as a watchdog, ensuring industry standards are upheld in a market increasingly focused on quality and authenticity.

Additives in 100% Agave Tequila: A Controversial Topic

The claim that the CRT permits up to 1% of any 100% agave spirit to consist of additives (glycerin, caramel coloring, oak extract, and sugar-based syrup) without changing the label has sparked significant debate. According to NOM-006-SCFI-2012, 100% agave tequila is defined as obtained exclusively from the distillation of fermented must or extract from Agave tequilana weber, blue variety, “without any addition of other alcoholic beverages or other substances that modify its nature” (section 4.1.3), suggesting additives are prohibited (Tequila.net: What are the regulations governing Tequila?). However, industry sources, such as SevenFifty Daily: The 11 Best Additive-Free Tequilas According to Experts, claim the CRT allows up to 1% additives without disclosure, particularly for consistency and color adjustments. This contradiction is evident in reports like Bottle Raiders: Additives in Your Tequila? Here’s How to Find Out, which note that top-tier tequilas may include saccharine sugars and fake oak aromas without labeling, raising transparency concerns.

Further complicating matters, since 2013, white (blanco) 100% agave tequilas have been banned from containing additives, with only water allowed post-distillation, as per Experience Agave: Mexico Bans Additives in Blanco Tequilas. Yet, the application to aged tequilas (reposado, añejo) remains unclear, with some sources suggesting small amounts may be tolerated, especially for mimicking barrel-aging effects, as discussed in Tasting Table: The Truth About Tequila Additives. This ambiguity has led to initiatives like the Additive-Free Alliance by Tequila Matchmaker, which certifies additive-free brands, drawing CRT criticism for causing consumer confusion, as reported in VinePair: Tequila Matchmaker Removes All Tequila Brands From Its Additive-Free List. The CRT’s recent efforts to develop its own additive-free verification program, as mentioned in Bottle Raiders: Tequila Regulatory Council Denounces Additive-Free Labeling, highlight ongoing efforts to clarify regulations, though details remain pending as of March 31, 2025.

Industry Dynamics and Consumer Implications

The debate over additives reflects broader industry dynamics, with consumer interest shifting toward additive-free options, as noted in Liquor.com: Is ‘Additive-Free’ Tequila the New 100% Agave?. This shift is driven by perceptions of authenticity, with brands like Fortaleza and Cazcanes adopting additive-free labels, yet facing CRT scrutiny, as seen in Reddit: The CRT really doesn’t want people thinking about or talking about additive free tequila. The CRT’s stance, condemning independent labeling, aims to maintain regulatory control, but it has fueled tensions with small brands, as reported in SevenFifty Daily: How the Conflict in Additive-Free Tequila Is Hurting Small Brands. This conflict underscores the need for greater transparency, with consumers increasingly seeking clarity on what’s in their tequila, especially given the potential impact on taste and health, as discussed in Food and Wine: Tequila Purists, Avert Your Eyes — Not All Additives Are Necessarily Bad.

Summary Table of Tequila Categories and Additives

To organize the regulatory landscape, here’s a detailed breakdown:

Category Agave Content Allowed Additives Notes
Tequila (Mixto) Minimum 51% Yes, up to 49% can be other sugars Can be bottled outside Mexico in bulk, as per NOM
Tequila 100% Agave 100% No, according to NOM, no substances that alter its nature Must be bottled in Mexico, no additives allowed
Tequila Blanco 100% 100% No, only water allowed after distillation No aging, additives banned since 2013
Tequila Reposado/Añejo 100% or Mixto Yes, in mixto; unclear for 100% according to NOM May include adjustments with additives in mixto, debate for 100% aged

This table highlights the regulatory distinctions and the ongoing uncertainty around aged 100% agave tequilas, reflecting the complexity of CRT oversight.

Conclusion and Future Outlook

Based on NOM-006-SCFI-2012 and official statements, 100% agave tequila should not contain additives, and the claim of allowing up to 1% without label changes is incorrect. However, industry practices and debates, particularly for aged tequilas, suggest possible unregulated use, emphasizing the need for enhanced transparency and regulatory clarity. As of March 31, 2025, the CRT’s ongoing efforts to develop an additive-free certification program could address these issues, but current consumer and producer tensions indicate a challenging path ahead, as reported in Sip Outsider: Additive-Free Tequila Certification Added to CRT Endorsement Marks. This comprehensive analysis underscores the CRT’s critical role and the evolving nature of tequila regulation, offering insights for consumers and industry stakeholders alike.

The OFFICIAL MEXICAN STANDARD NOM-006-SCFI-2012 ALCOHOLIC BEVERAGES-TEQUILA SPECIFICATIONS uses the term “mellowing” to describe a procedure to soften the flavor of the Tequila, through the addition of one or more of the following
ingredients:

  • Caramel coloring
  • Natural oak or Encino oak extract (holm or holm oak extract)
  • Glycerin
  • Sugar-based syrups