Lysozyme, which is listed on the same page, used to require TTB permission…but apparently no longer does (shows how often I look at it). Because of that, I am guessing it is because of the new nature of the product…but that is just a guess on my part.
The TTB essentially operates on “explicit” permissions rather than “implicit.” In other words, you can only add approved materials and only for the reasons allowed. For example, there are products on the market that are essentially yeast extracts that allow one to bypass traditional cold stability methods. This is very desirable for small producers of, say, Sauvignon blanc who might not have the appropriate infrastructure to cold stabilize it the old-fashioned way. Yeast hulls and nutrients are allowed materials but only to facilitate fermentation…and these products are added well after fermentation is complete. Thus, they require a similar letter.
This process was created because the approval of new materials can take quite a while. If the manufacturer can prove they are GRAS (generally regarded as safe), the TTB will usually allow additions with the letter petition.