As for diabetics…I work indirectly with some health advocacy groups, especially diabetes organizations, and they are chiefly concerned with carbohydrate counts in food and drink. Menus and daily food allowances for diabetics are all based around carbohydrates, not sugar. Controlling carbohydrates reflects the process of eating, the release of glucose and the subsequent dumping (or lack of) of insulin to temper this.

Allergens? Think peanuts, sulfites, artificial sweeteners, even dairy products.

I don’t know of any research to back this up but I’d love to see a survey done on this.

As for drawing a line, I was under the impression that the industry was going to be given some leeway as to the size of the table. Smaller type might be harder to read but having some experience with graphic design, I’d be surprised if they couldn’t make it work somehow.

I don’t know about allergens (we have designated gluten-free beer; are there are other allergies I don’t know about?) but I would like to see a full list of ingredients. I’m a big fan of organic beer and wine that doesn’t contain sulfites and while that information is included on many bottles, I’d like to see it all put in one place for easy viewing.

The additives definitely seem like a good place to draw the line. If it’s removed during filtration, I would argue that while its part of the process it’s hardly an ingredient.

Then you come to additives used during the production process, the polymer polyvinylpolypyrrolidone (PPVP) for beer filtering, for instance. If it’s added to beer to aid filtration and then removed during filtration, should it be included as an “ingredient” in beer?

To get the latest feel for what’s on the minds of the folks at TTB on the labeling issue, go to ttb.gov and do a search for “27 CFR Parts 4, 5, 7, and 24 Labeling and Advertising of Wines, Distilled Spirits and Malt Beverages; Proposed Rule.” This comes out of the Federal Register, dated July 31, 2007. It’s about 24 pages long but it does answer a lot of questions and addresses some “what if’s?” too.

As for the cost issue — very much on the minds of smaller wine and beer operations…pages 41871, 41872 and 41873 directly address this. It’s too lengthy to go into here, but the TTB does propose a 3-year implementation of any label changes. They also are relying on an analysis made by the FDA, titled “FDA Labeling Cost Model Final Report” (revised January 2003) that attempts to soften the economic blow of labeling changes and associated costs.

1. Would you like to see basic nutritional information on alcohol beverages?
2. Would you be willing to pay 5% more to cover it?

At least to me, that would be telling. Offering 1 without 2 is like asking a kid, “do you want free candy?”

Vintners and brewers, however, like to bring up the health-related arguments of why their products are “good” for consumers (resveratrol, phenols, flavonoids, vitamin B compounds, etc.) and yet avoid any attempt to get them to add nutritional info on their products, or simply their websites or POP materials.

You can’t have it both ways.

I will admit, however, that some regional brewers who refused to provide me with any nutritional information about their products just a few year ago when I wrote my first book on beer and nutrition, have seen the light and are now quite cooperative in providing info about their products.

You can’t fight the feds nor the wants of the marketplace. Consumers want nutritional information on their favorite beer, wines and distilled products. Those who provide this info will be the ones who will win in sales.