2007-12-16-TTBLabelingProposal

I am an interested consumer and am not otherwise connected with the beverage industry. I think better labeling is important, but the current proposal has some major flaws.

My views on the proposed rules are:

1. The percentage of alcohol by volume should be the only description of the amount of alcohol in a bottle.

In general, consumers only drink by any form of standard measure when they're being served in a restaurant or bar (where they're not going to see the label anyway). In my experience, what most consumers care about when it comes to alcohol is X is stronger than Y. This is best described as a percentage of alcohol by volume instead of having some number of grams for a given bottle size and having the consumer do the calculations as to which is stronger. While it is convenient to have it on the product label (as it's easy to find), I see no reason to force it to be there (as long as it's somewhere on the bottle).

Also, terms like "proof" are a source of unnecessary confusion and should be done away with. A single way of describing the amount of alcohol in the bottle that's consistent with the rest of the world is the simplest and least confusing way of informing the consumer and the least burden on the beverage industry.

2. All beverages containing more than a minimum (1% or 2%) of alcohol must have a percent of alcohol by volume label.

Currently, there are exceptions for malted beverages. These should be done away with so that consumers can easily see how much alcohol they're consuming regardless of beverage. I encourage this one particularly as I've seen several pranks involving serving an unsuspecting consumer (usually a college student) a high strength beer which caused them to get far more intoxicated than they were intending.

This could be expressed as "%Alc/Vol" which I have seen in some other countries as a way to convey meaning without taking up lots of space.

3. Horizontal labeling should be permitted for all bottle sizes and shapes.

Given the use of the label on most wines and the amount of space a large chart would take up (especially if it's filled with a large number of zero value items), it would be valuable to the industry to allow horizontal labeling. Consumers should still be able to get the information they need out of such labeling so it would benefit the manufacturers without harming the consumer.

4. All volumes should be listed in milliliters (expressed as mL) and weights in grams (expressed as g).

Most alcohol (with the exception of malt beverages) is measured in milliliters. To make it easier on consumers and generally more consistent with other beverage measurements, all alcoholic beverages should have their volumes measured in mL instead of a mixture of mL and US fl oz depending on what's in the bottle.

If alcohol is to be listed as an item on the bottle, it should be measured in grams rather than fluid ounces to be consistent with the labels on other food items. If it is decided that the amount of alcohol should be listed as a raw volume (which I disagree with), it should be listed in milliliters (mL) so it matches the volume on the front of the bottle and consumers can work out the percentage of alcohol by volume.

5. Serving sizes or "standard drink" definitions (particularly with diagrams) are of little to no use (and are sometimes misleading) to consumers and should be avoided.

Diagrams take up a lot of room but convey very little extra meaning. For drinks like beer that come in a standardized bottle size, the serving size is that bottle and having an extra image of the bottle and it's volume on the back conveys no extra useful meaning. I agree with the note in the document that suggests there's likely to be confusion by putting serving sizes and standard drink definitions on bottles.

As pointed out by another submitter, I expect the serving sizes to be most misleading near the edges of a given range where changing 1% or 2% of the alcohol by volume doubles the serving size (and many consumers would take the serving size literally instead of just a guideline).

6. An ingredient list should be required

Whether it's the ability to test for or an actual increase in the number of allergies, there's certainly more consumer awareness about them. This makes it important to have ingredient lists on all products made up of multiple items that might be consumed. It is also useful to consumers to have such lists as many consumers dislike consuming products with various ingredients (for example high fructose corn syrup) so it would help them in choosing between two beverages.

7. Given the difference in the way alcohol and carbohydrates are metabolized, each should be listed separately when describing Calories.

Many other respondents have pointed out that alcohol is metabolized differently and does not have the same effect on the body for those who are trying to count Calories or kilojoules as a way of keeping their weight under control. As the energy from carbohydrates is more interesting for those watching their weight, it should be listed separately (and possibly be the only listing made) if such labeling requirements are to be put in place.

8. There should be a minimum production amount (for example 50,000 liters which is a little over the 45,000 liters contained in 5,000 cases of wine in standard 750mL bottles) before extra information such as Calories is required so as to not put undue pressure on small business.

Given the expense, particularly for small runs of a distillation, brew or wine I believe it would impose undue penalty on small businesses and also reduce their ability to experiment. This would hurt both the wine makers / brewers and the consumer.

If the TTB goes ahead with requiring such labels on all bottles, a generic label for a given class of beverage should be considered and permitted for smaller makers.

9. Any value that has a value of zero (or rounds to zero) should be excluded from the requirements for labeling.

This would reduce the expense of such a label and also reduce the amount of noise a consumer has to wade through to get information they're able to use. Printing lots of zeros is a waste of resources and makes finding the actual information more difficult for the consumer.