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	<title>Comments on: Small Business Administration Comment; Top 3 Things to Know</title>
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	<description>Distilling a million label approvals down to the ones that affect you.</description>
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		<title>By: Wine News by Alana Zerbe / Epikur Magazine &#124; Epikur Magazine</title>
		<link>http://www.bevlaw.com/bevlog/alcohol-beverages-generally/small-business-administration-comment-top-3-things-to-know/comment-page-1#comment-12886</link>
		<dc:creator>Wine News by Alana Zerbe / Epikur Magazine &#124; Epikur Magazine</dc:creator>
		<pubDate>Thu, 02 Feb 2012 00:21:45 +0000</pubDate>
		<guid isPermaLink="false">http://www.bevlaw.com/bevlog/?p=1682#comment-12886</guid>
		<description>[...] Wine and spirits labels may undergo big changes in the future.  The excellent Bevlog reports. [...]</description>
		<content:encoded><![CDATA[<p>[...] Wine and spirits labels may undergo big changes in the future.  The excellent Bevlog reports. [...]</p>
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		<title>By: Wine News : Epikur Magazine</title>
		<link>http://www.bevlaw.com/bevlog/alcohol-beverages-generally/small-business-administration-comment-top-3-things-to-know/comment-page-1#comment-6494</link>
		<dc:creator>Wine News : Epikur Magazine</dc:creator>
		<pubDate>Mon, 18 Jul 2011 20:07:42 +0000</pubDate>
		<guid isPermaLink="false">http://www.bevlaw.com/bevlog/?p=1682#comment-6494</guid>
		<description>[...] Wine and spirits labels may undergo big changes in the future.  The excellent Bevlog reports. [...]</description>
		<content:encoded><![CDATA[<p>[...] Wine and spirits labels may undergo big changes in the future.  The excellent Bevlog reports. [...]</p>
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		<title>By: Wine News : Epikurus</title>
		<link>http://www.bevlaw.com/bevlog/alcohol-beverages-generally/small-business-administration-comment-top-3-things-to-know/comment-page-1#comment-1623</link>
		<dc:creator>Wine News : Epikurus</dc:creator>
		<pubDate>Wed, 30 Jun 2010 16:14:24 +0000</pubDate>
		<guid isPermaLink="false">http://www.bevlaw.com/bevlog/?p=1682#comment-1623</guid>
		<description>[...] Wine and spirits labels may undergo big changes in the future.  The excellent Bevlog reports. [...]</description>
		<content:encoded><![CDATA[<p>[...] Wine and spirits labels may undergo big changes in the future.  The excellent Bevlog reports. [...]</p>
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		<title>By: admin</title>
		<link>http://www.bevlaw.com/bevlog/alcohol-beverages-generally/small-business-administration-comment-top-3-things-to-know/comment-page-1#comment-822</link>
		<dc:creator>admin</dc:creator>
		<pubDate>Mon, 20 Apr 2009 11:12:10 +0000</pubDate>
		<guid isPermaLink="false">http://www.bevlaw.com/bevlog/?p=1682#comment-822</guid>
		<description>Moating seems too benign. Isn&#039;t &quot;moating&quot; good and what a good company &lt;em&gt;should &lt;/em&gt;be doing? Gumpinski&#039;s earlier point, to the contrary, seemed to suggest that the big-company-proponents were pushing something nefarious.</description>
		<content:encoded><![CDATA[<p>Moating seems too benign. Isn&#8217;t &#8220;moating&#8221; good and what a good company <em>should </em>be doing? Gumpinski&#8217;s earlier point, to the contrary, seemed to suggest that the big-company-proponents were pushing something nefarious.</p>
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		<title>By: Gumpinski</title>
		<link>http://www.bevlaw.com/bevlog/alcohol-beverages-generally/small-business-administration-comment-top-3-things-to-know/comment-page-1#comment-802</link>
		<dc:creator>Gumpinski</dc:creator>
		<pubDate>Mon, 13 Apr 2009 21:53:58 +0000</pubDate>
		<guid isPermaLink="false">http://www.bevlaw.com/bevlog/?p=1682#comment-802</guid>
		<description>I kind of like reader&#039;s unintentional suggestion of &quot;Moating.&quot; It definitely describes what they&#039;re doing.</description>
		<content:encoded><![CDATA[<p>I kind of like reader&#8217;s unintentional suggestion of &#8220;Moating.&#8221; It definitely describes what they&#8217;re doing.</p>
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		<title>By: A micro winery owner</title>
		<link>http://www.bevlaw.com/bevlog/alcohol-beverages-generally/small-business-administration-comment-top-3-things-to-know/comment-page-1#comment-801</link>
		<dc:creator>A micro winery owner</dc:creator>
		<pubDate>Mon, 13 Apr 2009 19:37:51 +0000</pubDate>
		<guid isPermaLink="false">http://www.bevlaw.com/bevlog/?p=1682#comment-801</guid>
		<description>As a micro winery that produces small lots of wine (25-30 cases) for marketing trials, perfecting a blend or new wine, or for offering these as special wines for club members only, having to absorb $750 per label is difficult. On a 25 case lot you are looking at $30 per case for a wine you may only be selling for 1 few dollars over costs to begin with, which either means absolutley no profit, a loss, raising prices or needing to drop a very valid business process and plan. 

Some of us are in it for the romance of wine, the change in lifestyle or the opportunity to create something, as opposed to making massive amounts of money.

Maybe there needs to be a cutoff point for compliance? If you make less than 100 cases of a wine, you are exempt from providing the information.

I also believe there needs to be an allowance if you are changing nutritional information, you do not have to re-submit labels for approval, just like a vintage year change. This would help reduce the costs for the winery when merely updating information.</description>
		<content:encoded><![CDATA[<p>As a micro winery that produces small lots of wine (25-30 cases) for marketing trials, perfecting a blend or new wine, or for offering these as special wines for club members only, having to absorb $750 per label is difficult. On a 25 case lot you are looking at $30 per case for a wine you may only be selling for 1 few dollars over costs to begin with, which either means absolutley no profit, a loss, raising prices or needing to drop a very valid business process and plan. </p>
<p>Some of us are in it for the romance of wine, the change in lifestyle or the opportunity to create something, as opposed to making massive amounts of money.</p>
<p>Maybe there needs to be a cutoff point for compliance? If you make less than 100 cases of a wine, you are exempt from providing the information.</p>
<p>I also believe there needs to be an allowance if you are changing nutritional information, you do not have to re-submit labels for approval, just like a vintage year change. This would help reduce the costs for the winery when merely updating information.</p>
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		<title>By: A Small Tour Into the Guinness Beer Brewing Industry &#124; Beer Keg</title>
		<link>http://www.bevlaw.com/bevlog/alcohol-beverages-generally/small-business-administration-comment-top-3-things-to-know/comment-page-1#comment-798</link>
		<dc:creator>A Small Tour Into the Guinness Beer Brewing Industry &#124; Beer Keg</dc:creator>
		<pubDate>Sun, 12 Apr 2009 23:00:02 +0000</pubDate>
		<guid isPermaLink="false">http://www.bevlaw.com/bevlog/?p=1682#comment-798</guid>
		<description>[...] Small Business Administration Comment; Top 3 Things to Know &#8230; [...]</description>
		<content:encoded><![CDATA[<p>[...] Small Business Administration Comment; Top 3 Things to Know &#8230; [...]</p>
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		<title>By: Reader</title>
		<link>http://www.bevlaw.com/bevlog/alcohol-beverages-generally/small-business-administration-comment-top-3-things-to-know/comment-page-1#comment-796</link>
		<dc:creator>Reader</dc:creator>
		<pubDate>Sun, 12 Apr 2009 15:34:25 +0000</pubDate>
		<guid isPermaLink="false">http://www.bevlaw.com/bevlog/?p=1682#comment-796</guid>
		<description>Gumpinski makes a great point. I haven&#039;t been able to stop thinking about it since.

I propose T-BAGGING as the word for this. Here&#039;s why it may fit:

1. T is the symbol for AT&amp;T, the biggest, baddest monopolist during much of the nation&#039;s history (arguably).

2. The evidence is here:  http://www.slate.com/id/2156918/pagenum/all/. AT&amp;T mounted a herculean, many-decade effort to close out all long-distance competitors, on some wacked out theory that it would break the system. To what extent did the government watch their back and play along? Is there a better example of a company that carefully arranged the laws as a moat around their castle?

3. I admit that &quot;tea bagging&quot; is all the rage this weekend, as explained here:  http://www.examiner.com/x-1765-Underground-Examiner~y2009m4d10-Who-is-going-to-tell-them-Teabagging-explained. But that makes it more, not less . . . fitting. More than a few small companies will choke on what Diageo is dangling.

4. The similarity to sandbagging doesn&#039;t hurt either.

What do you think Gumpinski and others? Does the bag fit? By the way, this is not meant to imply that the big company proponents of new labeling are acting in other than a rational manner.</description>
		<content:encoded><![CDATA[<p>Gumpinski makes a great point. I haven&#8217;t been able to stop thinking about it since.</p>
<p>I propose T-BAGGING as the word for this. Here&#8217;s why it may fit:</p>
<p>1. T is the symbol for AT&amp;T, the biggest, baddest monopolist during much of the nation&#8217;s history (arguably).</p>
<p>2. The evidence is here:  <a href="http://www.slate.com/id/2156918/pagenum/all/" rel="nofollow">http://www.slate.com/id/2156918/pagenum/all/</a>. AT&amp;T mounted a herculean, many-decade effort to close out all long-distance competitors, on some wacked out theory that it would break the system. To what extent did the government watch their back and play along? Is there a better example of a company that carefully arranged the laws as a moat around their castle?</p>
<p>3. I admit that &#8220;tea bagging&#8221; is all the rage this weekend, as explained here:  <a href="http://www.examiner.com/x-1765-Underground-Examiner~y2009m4d10-Who-is-going-to-tell-them-Teabagging-explained" rel="nofollow">http://www.examiner.com/x-1765-Underground-Examiner~y2009m4d10-Who-is-going-to-tell-them-Teabagging-explained</a>. But that makes it more, not less . . . fitting. More than a few small companies will choke on what Diageo is dangling.</p>
<p>4. The similarity to sandbagging doesn&#8217;t hurt either.</p>
<p>What do you think Gumpinski and others? Does the bag fit? By the way, this is not meant to imply that the big company proponents of new labeling are acting in other than a rational manner.</p>
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		<title>By: Wine News &#124; The Philly Wine Website</title>
		<link>http://www.bevlaw.com/bevlog/alcohol-beverages-generally/small-business-administration-comment-top-3-things-to-know/comment-page-1#comment-795</link>
		<dc:creator>Wine News &#124; The Philly Wine Website</dc:creator>
		<pubDate>Sun, 12 Apr 2009 15:24:20 +0000</pubDate>
		<guid isPermaLink="false">http://www.bevlaw.com/bevlog/?p=1682#comment-795</guid>
		<description>[...] Win&#173;e an&#173;d&#173; sp&#173;irits lab&#173;els may u&#173;n&#173;d&#173;ergo&#173; b&#173;ig ... i&#173;n the&#173; futur&#173;e&#173;. The&#173; e&#173;xc&#173;e&#173;l&#173;l&#173;e&#173;nt B&#173;evl&#173;o&#173;g re&#173;po&#173;&#173;rts&#173;. [...]</description>
		<content:encoded><![CDATA[<p>[...] Win&#173;e an&#173;d&#173; sp&#173;irits lab&#173;els may u&#173;n&#173;d&#173;ergo&#173; b&#173;ig &#8230; i&#173;n the&#173; futur&#173;e&#173;. The&#173; e&#173;xc&#173;e&#173;l&#173;l&#173;e&#173;nt B&#173;evl&#173;o&#173;g re&#173;po&#173;&#173;rts&#173;. [...]</p>
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		<title>By: Anonymous California winery</title>
		<link>http://www.bevlaw.com/bevlog/alcohol-beverages-generally/small-business-administration-comment-top-3-things-to-know/comment-page-1#comment-794</link>
		<dc:creator>Anonymous California winery</dc:creator>
		<pubDate>Sat, 11 Apr 2009 20:53:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.bevlaw.com/bevlog/?p=1682#comment-794</guid>
		<description>We are owners of two small wineries. One has annual revenues of ~800K, makes about 20 wines each year. The other has revenues of about $220K and makes 15 wines per year, averaging just 100 cases of each wine. 

We have shopped around for the cost of analysis, and if we do the alcohol measurement ourselves, we can have the necessary analyses done for about $350-500/wine. Add to this the cost of revamping every label, including new steel rule dies for new label sizes, and the hassle of re-approving every label, and we estimate this will cost each winery about $10,000 to $15,000 per year. This will not drive the larger winery out of business, but it will mean that we will have to reduce salaries for key employees or ask the survivors to take on additional work if others are dropped from the payroll. For the smaller winery, this is at least half of our annual operating income, and would mean we could no longer pay a winemaker to produce the excellent wines we now make. Thus, the smaller winery would likely disappear from the marketplace, along with the revenue we have enjoyed for years. 

The administrative burden is harder to estimate, but ordering all the analyses, collating the data and funneling it to the correct wine each year is not insignificant.</description>
		<content:encoded><![CDATA[<p>We are owners of two small wineries. One has annual revenues of ~800K, makes about 20 wines each year. The other has revenues of about $220K and makes 15 wines per year, averaging just 100 cases of each wine. </p>
<p>We have shopped around for the cost of analysis, and if we do the alcohol measurement ourselves, we can have the necessary analyses done for about $350-500/wine. Add to this the cost of revamping every label, including new steel rule dies for new label sizes, and the hassle of re-approving every label, and we estimate this will cost each winery about $10,000 to $15,000 per year. This will not drive the larger winery out of business, but it will mean that we will have to reduce salaries for key employees or ask the survivors to take on additional work if others are dropped from the payroll. For the smaller winery, this is at least half of our annual operating income, and would mean we could no longer pay a winemaker to produce the excellent wines we now make. Thus, the smaller winery would likely disappear from the marketplace, along with the revenue we have enjoyed for years. </p>
<p>The administrative burden is harder to estimate, but ordering all the analyses, collating the data and funneling it to the correct wine each year is not insignificant.</p>
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