Does Adding Water to Dilute Vinegar Require Labeling as an Ingredient?

Hi Everyone,

200 grain vinegar is purchased and water is added in house to make it 50 grain for use in different product. For labeling, I want to suggest that this added water would have to be declared on the ingredients list based on the FDA guidance linked below. Someone before me suggested that this could be labeled as just vinegar, without the water added before. There is another source of water in the formula.

CPG Sec 555.875 Water in Food Products (Ingredient or Adulterant) | FDA

What I want to know is, are there other pieces of evidence I can use to support my suggestion, as this mentions rehydrating dry ingredients only? Or would anyone have a suggestion/justification of why this was passed before? 

Any knowledge contributed is much appreciated. 

Apologies, I see mention of concentrated ingredients in the guidance as well, so my question now is: Is there a more recent guidance or will this hold? I see that this one is last updated in 2015. 

I dont think that your attachmanet applies.   You are not dilluting for gain, but to make an ingredient / WIP that is usable to your product.   

My first thought was to just label it as vinegar as i believe you are just making a more dilluted vinegar.  Then I found this obscure rule (I think it more applies to sellable containers and not ingredient statements in products for which it is used).   

https://www.fda.gov/.../71937/download

You could go that route as well. ((X vinegar (diluted with water to X % acid)).

or seek clarification from a regulator - IMO opinion, i dont think they are going to have an issue as long as the ingredients are accounted for.  

I think you are worried about rules that are meant to decieve or cheat the customer, thats not what you are doing.  

more info on vinegar than I care to read:  https://versatilevin...-March-2014.pdf