As you may know, wine sold in the European Union that was packaged or labeled after December 8, 2023 is now required to provide nutritional data, calorie counts, certain additives, and other information. Some of it needs to be on the label itself; the rest can be provided on a website, accessed, perhaps, by using a QR code.
The United States is now considering whether it should require wine to provide more information.
On January 31, 2024, The Department of the Treasury’s Alcohol and Tobacco Tax and Trade Bureau (TTB) announced that it will be holding listening sessions and accepting comments on the labeling of wine, distilled spirits, and malt beverages. This announcement stems from a 2022 report recommending that TTB consider new rules.
The law currently does not require alcohol beverage labels to disclose a full list of ingredients, any major food allergens, or nutritional information.
TTB specifically wants information on:
1. Do consumers believe that they are adequately informed by the information currently on alcohol beverage labels?
2. Is alcohol content per serving and nutritional information important for consumers in deciding whether to buy or consume an alcoholic beverage?
3. Would a list of ingredients and/or major food allergens be important information for consumers? If so, in what ways would it help and in what ways could it be misleading?
4. What types of nutritional information should be included?
5. Would requiring this information on labels increase the cost and if so by how much?
6. To what extent are businesses following voluntary guidelines for this information?
7. Are there alternative ways to provide this information, such as by using a QR code?
8. How would any new mandatory labeling requirements particularly affect small and new businesses?
Benefits and Drawbacks
There are pros and cons to requiring increased nutrition and other labeling on wine.
The pros include:
· Consumers could make more informed decisions about what they might consume.
· The information would correct misunderstandings about wine. For example, Dr. Liz Thach, MW, professor and President of the Wine Market Council, noted in Forbes that many are confused about whether sugars have been added (typically not) and the number of calories in a glass (typically less than what people often think).
· It would increase allergen safety and address dietary concerns, such as whether milk or eggs were used in the winemaking process.
· The increase in comfort level regarding what’s in a wine could increase wine sales, a plus for the industry.
· It could enable high-quality artisanal producers to distinguish themselves.
· The increased transparency could make marketing more honest (i.e., whether a “clean” or “natural” wine is actually different from “other” wines).
Here are some cons:
· There would be increased administrative and testing costs, which could be passed down to consumers.
· Too much information, including lists of allowed preservatives and other additives, can be unnecessarily confusing, disconcerting, and/or daunting (such as including acetaldehyde (used for color stabilization) or polyvinylpyrrolidone (used to remove heavy metal ions).
· It could disproportionately hurt smaller producers, which may have a harder time complying with stricter rules.
· Some of the information, such as calorie counts, may be less useful overall and may be ignored or even detrimental.
· While more consumers would like this information than in the past, apparently the majority of them still don’t care.
Why You Should Make Your Voice Heard Re What You Want on a Wine Label
People should weigh in on the wine labeling debate. We don’t always get the opportunity to tell the government what we think, and we should take advantage of it. TTB wants our input. And we’ll be directly affected by any resulting decisions that TTB will make.
But not that many people thus far have taken TTB up on its offer. As of February 22, 2024, there were only 59 comments submitted. These types of governmental notices often receive hundreds if not thousands of comments.
Tips on How to Submit a Comment
As a long-time reader of the Federal Register, the official daily publication of the federal government where TTB posted its announcement, I do have some pointers for people considering filing a comment:
· You do not have to respond to all of TTB’s questions. Just weigh in on what you want to address. For example, the venerable wine writer Alder Yarrow, author of the award-winning publication Vinography submitted a comment supporting ingredient labeling for wine while also providing advice to TTB regarding the extent to which information should be required. He also pointed out the unique aspects of wine manufacture and noted that ingredient labeling would reduce consumers’ misconception that wine is less healthy than some other beverages. Some commenters have submitted very short comments that focus on just one issue, such as their views on sugar content on labels.
· We aren’t limited to the labeling questions TTB posted above. For instance, TTB also wants our opinions about advertising alcohol content and nutritional information.
· If you have a rationale and/or supporting documentation for your position, include it. TTB would like that information, as well.
· The comments will be public. However, they can be anonymous. In fact, many of those already posted are.
· Comments can be submitted on the website or via postal mail. The link is: https://www.federalregister.gov/documents/2024/01/31/2024-01855/labeling-and-advertising-of-wine-distilled-spirits-and-malt-beverages-with-alcohol-content
The deadline for submitting written comments is March 29, 2024.
Take the plunge! Make your voice heard re what you want on a wine label. I plan to weigh in, too.
What do you think of TTB’s request for comments? And what do you think will happen next? Let us know your thoughts. Send us a message at info@winewithourfamily.com.
If you enjoyed this post, visit our website at www.winewithourfamily.com and take a look at some of our related articles:
6 Ways the New Public Health Anti-Alcohol Warnings May Affect Consumers
Should the U.S. Postal Service Be Able to Deliver Alcohol?
