To All Concerned Drinkers Out There:

The Alcohol and Tobacco Tax and Trade Bureau (TTB) is the government entity that controls the label approval of all wine, spirit, and malt beverage products in the United States.  Without approval from the TTB, excepting some very special circumstances, wine, spirits, and malt beverages cannot be sold or imported into the United States.  Obtaining this approval requires the submittal of the labels that will appear on the bottle, box, or can and any other appropriate paperwork to back up whatever claims are made on the label (ie. organic statements, late harvest statements, aged statements).  The TTB then gets back to you in about 10 days if submitted online or around a month if submitted on paper.  If your labels are rejected you have to change them and resubmit to the TTB until they are approved.

The TTB has myriad regulations on the content of labels.  My personal specialty lies in the area of wine labeling.  Some of these regulations are simple:  the Brand Name of the wine must appear on the front label, the Government Warning must appear in type of no less that 2mm high (for 750ml bottles), if the wine is imported it must say Product of whatever country it is coming from.  Other regulations are relatively silly and useless:  The alcohol content must appear in type no less that 1.5mm high and no more that 3mm on the front label (on the back label it may appear in any height or not at all) and must read Alc. X% by Vol., or X% Alc./Vol., simply X% Alc. or X% Vol. is not good enough, the Class/Type (ie. Red Wine) must appear in direct conjunction with the appellation of origin (ie. Cotes du Rhone); however, if grape varietals are listed they supersede the class/type and therefore must be at least 2mm high, in direct conjunction with the appellation of origin, and must be twice as big as all other surrounding text.  The words Power, Intense, and Strong cannot be used to describe a wine as “mislead” the consumer into thinking the wine has the alcohol content of a spirit (um…if you don’t know that wine has less alcohol than vodka you should leave the liquor store now).  With all these regulations sitting around it is easy for a perfectly good and understandable wine label to get rejected and force the printer to change their plans.

The TTB is now looking at a new way to tie more bureaucratic tape around the alcoholic beverage industry.  The TTB has proposed that all alcoholic beverage labels now contain a separate Serving Facts Panel which would include alcohol content , calories, carbohydrates, fat and, protein (and whatever else they choose to sneak in there).  This would force all producers of wine to have quantitative analysis performed on their wine and new labels created for all their bottles.  What’s more, given the nature of wine and other spirituous products, the analysis may have to be performed each year as the composition changes with every vintage.  This not only takes up valuable time, but costs a good deal of cold hard cash.  Small producers, many of who are subsistence farmers, especially in the newer wine producing countries in South America, are not going to be able to afford these extra costs and will have to pass this cost along to the consumer.  Do you really want to be paying more for wine just so you can have a calorie count on the bottle?  In addition to the immediate cost to the consumer one must think of the tax dollars that will be spent on this project.  The TTB’s label approval is a free “service” and so when more information is needed on the labels and all wines have to get new approval several things may happen:  the TTB begins to charge for label approval (these costs will invariably be passed to the consumer by the supplier), the TTB hires more Specialists costing tax payers more money, the TTB hires no new Specialists and is summarily bogged down by the additional work (ie. the passport problem we are having currently) making the label approval process even longer than it already is.

One has to wonder who this new rule would actually help.  Does it help the obese person who wants to slim down?  Somehow I doubt that an obese person who enjoys his/her drink is all of a sudden going to stop because there is a calorie count on the bottle.  Everyone knows alcohol is full of empty calories (and if you don’t you shouldn’t be eating or drinking anything, do us a favor and allow yourself to slowly starve).  Will this help the concerned parent pick out “low alcohol” beverages for their children?  Well, no, since children aren’t supposed to be drinking anyway, and also the alcohol content is already on the bottle (why do we need to list it again).  This will definitely not help any small producers of alcoholic products; enjoy watching the price of small production wine, microbrews, and unique spirits skyrocket.  The only people I could possibly see this helping are large companies that can pay to have analysis done without changing the cost of their product.  This will, of course, give a greater advantage to those companies that produce large amounts of uninspiring, consistently sub-par, drink. 

The TTB is currently eliciting public comment on their proposed rule.  I would encourage any hot-blooded American who feels the need to defend the alcohol industry from even more meddling than it is already subject to, to write in and let the TTB know how you feel.  You can find the Press Release at the following link http://www.ttb.gov/press/index.shtml, click on the link to “TTB Proposes Mandatory Alcohol Content Statement and Serving Facts Panel”.  All the information you need to submit a written comment is included in the Press Release. 

Don’t let The Man get you down, uncork a bottle and write a short comment to defend the Little Guy!