Tuesday, March 5, 2024

TTB Listening Sessions on Label Regulations

On January 1, 2024, the Alcohol, Tobacco, Tax and Trade Bureau (TTB) posted the following notice informing the public that The Alcohol and Tobacco Tax and Trade Bureau (TTB) will conduct virtual listening sessions to receive input from the public on labeling of wine, distilled spirits, and malt beverages to disclose per-serving alcohol and nutritional information, major food allergens, and/or ingredients.1
These listening sessions were intended to engage the public, including consumers, public health stakeholders, and industry members of all sizes, and facilitate the public's ability to provide input to inform rulemaking.
There were five points of discussion:
     1. Do consumers believe that they are adequately informed by the          information currently provided on alcohol beverage labels?
     2. Is alcohol content per serving, and nutritional information (such as          calories, carbohydrates, protein, and fat) per serving important for          consumers in deciding whether to purchase or consume a particular          alcohol beverage? Would a full list of ingredients, and/or major food          allergens, be important information for consumers in making their          purchasing or consumption decisions? In what ways would this          information be useful, and in what ways could it be misleading? Is some          of this information more important than others?
     3. What types of per-serving nutritional information, such as calories,          carbohydrates, protein, and fat, should be included?
     4. Would requiring this information on labels be expected to increase the          cost of the products and, if so, by how much? To what extent are          businesses already following voluntary guidelines for this information?          Are there alternative ways of providing the information, for example by          allowing information to be provided through a website using a quick          response code (QR code) or website address on the label?
     5. How would any new mandatory labeling requirements particularly affect          small businesses and new businesses entering the marketplace?
The listening sessions were held on the 28th and the 29th of February. Full disclosure, I did not attend the virtual session, but my newsfeed contained a link to someone who did. W. Blake Gray posted TTB Listens to Wine Industry on March 1, 2024. Here is what he reported back in his article.
  • Most consumers believe that they are not adquately informed by the information currently provided on an alcoholic beverage label
  • Diabetics would like to see the amount of residual sugar reported on the label
  • People with allergies expressed an interest in knowing what was in the alcoholic beverage; for example glycerin can be a life threatening allergen for some people
  • Some wanted the calorie information to be on the label
  • Small beer brewers expressed a concern that if information such as calorie content was required, the amount of changes that needed to be made to imprint a new can would be cost prohibitive
  • W. Blake Gray opined that ingredient labeling would be good for the industry but he didn't see that nutritional content would be necessary
The reason this listening session was held was that in Europe, nutrition information will soon be required but can be given in a QR code, not on the label itself. Ignacio Sanchez Recarte, representing 13 EU member states, suggested that the US adopt a similar system. A major advantage is that information that is online, but not printed, can be adjusted at the last minute when the results for a wine vary from what was expected.2
What are your thoughts?
References:
1. Labeling and Advertising of Wine, Distilled Spirits, and Malt Beverages With Alcohol Content, Nutritional Information, Major Food Allergens, and Ingredients.
2. W. Blake Gray, TTB Listens to Wine Industry, March 1, 2024.

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