Posts Tagged ‘serving facts/allergens’
Reps. Thompson and Radanovich Comment; Top 5 Things to Know
It is likely that all beer, wine and spirits labels will change dramatically in the near future. TTB has been working on new rules since CSPI and other groups submitted a petition in 2003. The new rules would require a “Serving Facts” panel on every container. This panel would include a lot more information, such as the typical serving size, number of servings per container, calories, carbohydrates, protein and fat. Because this is a big, controversial change, TTB has received more than 18,000 public comments during the past few years. There are far too many comments for most people to review, and so we will highlight and summarize the most noteworthy comments here. The most recent proposal and comments are here. This is comment 17 in a series; to see others, click on the “serving facts” tag below.
Representatives Mike Thompson (D-CA 1st) and George Radanovich (R-Mariposa) are co-chairmen of the Congressional Wine Caucus. Their 2-page comment said:
- This rule “could lead to the most significant revisions in wine label requirements in the history of the American wine industry.”
- It could “have a severely detrimental impact on the wine industry.”
- There is little evidence that consumers want or need additional information of this type, and TTB should balance this against the burden.
- TTB should make it voluntary, or allow the use of typical values rather than analytical values.
- The burdens are unreasonable. They could “easily reach into the hundreds of thousands of dollars for a medium sized winery.”
Related Posts:
Tags:
policy, serving facts/allergens
Posted in:
Email This Post
| 
Print This Post
|
PLCB and St. Supery Comments; Top 7 Things to Know
It is likely that all beer, wine and spirits labels will change dramatically in the near future. TTB has been working on new rules since CSPI and other groups submitted a petition in 2003. The new rules would require a “Serving Facts” panel on every container. This panel would include a lot more information, such as the typical serving size, number of servings per container, calories, carbohydrates, protein and fat. Because this is a big, controversial change, TTB has received more than 18,000 public comments during the past few years. There are far too many comments for most people to review, and so we will highlight and summarize the most noteworthy comments here. The most recent proposal and comments are here. This is comment 16 in a series; to see others, click on the “serving facts” tag below.
The Pennsylvania Liquor Control Board’s 2-page comment said:
- the rule should provide that a standard serving is 1.5 fluid ounces for spirits, 12 ounces for beer and 5 ounces for wine.
- the panel should explain that “a standard drink contains 0.6 fl. oz. of alcohol.”
- the Serving Facts panel should show the amount of alcohol per serving.
By contrast, St. Supery Winery’s 1-page comment said:
- the proposal is burdensome and would provide “no additional useful information to consumers.”
- Most back labels already need a UPC and a Government Warning and this additional information is likely to crowd out the product descriptions that consumers want.
- Wines fluctuate considerably from tank to bottling and this could require extra testing and expense.
- This will raise our costs; we will pass those along to wholesalers and they will get magnified along the way to consumers. Most consumers would rather have lower costs compared to extra, already-available information.
Are they right?
Related Posts:
Tags:
policy, serving facts/allergens, state
Posted in:
Email This Post
| Print This Post
|
Small Business Administration Comment; Top 3 Things to Know
It is likely that all beer, wine and spirits labels will change dramatically in the near future. TTB has been working on new rules since CSPI and other groups submitted a petition in 2003. The new rules would require a “Serving Facts” panel on every container. This panel would include a lot more information, such as the typical serving size, number of servings per container, calories, carbohydrates, protein and fat. Because this is a big, controversial change, TTB has received more than 18,000 public comments during the past few years. There are far too many comments for most people to review, and so we will highlight and summarize the most noteworthy comments here. The most recent proposal and comments are here. This is comment 16 in a series; to see others, click on the “serving facts” tag below.
The Small Business Administration’s 2-page comment said:
- information from WineAmerica indicates that the proposal would have a significant economic impact on a substantial number of small wineries, so the proposal can not be properly certified under the Regulatory Flexibility Act.
- TTB estimated that lab analysis would cost about $250 per product, but the comment suggests it would be closer to $750 per product.
- This suggest a 3.4% revenue impact for a very small winery (with $500,000 in revenue, about 15 products, and about $17,000 in new costs). This is significant and is not mitigated by a longer phase-in.
Is the SBA right?
Related Posts:
Tags:
policy, serving facts/allergens
Posted in:
Email This Post
| Print This Post
|
FIVS and CEPS Comments; Top 8 Things to Know
It is likely that all beer, wine and spirits labels will change dramatically in the near future. TTB has been working on new rules since CSPI and other groups submitted a petition in 2003. The new rules would require a “Serving Facts” panel on every container. This panel would include a lot more information, such as the typical serving size, number of servings per container, calories, carbohydrates, protein and fat. Because this is a big, controversial change, TTB has received more than 18,000 public comments during the past few years. There are far too many comments for most people to review, and so we will highlight and summarize the most noteworthy comments here. The most recent proposal and comments are here. This is comment 14 in a series; to see others, click on the “serving facts” tag below.
FIVS is a woldwide organization for all sectors of the alcohol beverage industry, with several in the European Union. FIVS’ 3-page comment said:
- The TTB proposal “has the potential to significantly increase the financial and logistical burdens on the global industry when there are alternative means to achieve the same ends with less detrimental impacts.”
- A new analysis for every product, at something like $250 per analysis, could lead to large costs and delays. In some cases, producers may need to adjust products to conform to already-printed labels.
- The need for extra data requires larger or more numerous labels; this is more expensive and may require new labeling equipment.
- TTB can mitigate the burden by making these labeling requirements voluntary, or by allowing the information to be posted on the internet. TTB should allow the linear format, and typical values rather than analytical values.
The European Spirits Organization – CEPS is the representative body for the spirits industry in Europe; it is comprised of 36 industry associations in 29 countries. CEPS’ 4-page comment said:
- “The most simple and transparent method [for comparing products] would be to relate all the nutritional information to a ‘standard drink’, ie to the volume of liquid at whatever strength containing 0.6 fl oz of absolute or pure alcohol.”
- “Alcoholic strength is almost infinitely variable” so the consumer “is faced with some difficult mental arithmetic in order to determine the amount of alcohol he/she is consuming.”
- TTB should make the new disclosures voluntary. But if TTB makes them mandatory, TTB should not require anything more than calories on spirits, in order to harmonize with new EU rules.
- TTB should allow 3-5 years to phase in the new rules, and containers up to 100 ml. should be exempt.
Are they right?
Related Posts:
Tags:
policy, serving facts/allergens
Posted in:
Email This Post
| Print This Post
|
DISCUS Comment; Top 6 Things to Know
It is likely that all beer, wine and spirits labels will change dramatically in the near future. TTB has been working on new rules since CSPI and other groups submitted a petition in 2003. The new rules would require a “Serving Facts” panel on every container. This panel would include a lot more information, such as the typical serving size, number of servings per container, calories, carbohydrates, protein and fat. Because this is a big, controversial change, TTB has received more than 18,000 public comments during the past few years. There are far too many comments for most people to review, and so we will highlight and summarize the most noteworthy comments here. The most recent proposal and comments are here. This is comment 13 in a series; to see others, click on the “serving facts” tag below.
The Distilled Spirits Council of the US (DISCUS) is a trade association representing spirits producers and marketers. DISCUS submitted a 14-page comment, plus 6 pages of footnotes and a 61-page survey making these points:
- Some DISCUS members market wine and beer, so DISCUS has a broad perspective.
- DISCUS opposes the proposed Serving Facts panel, whether required or optional. It will not provide sufficient information unless it explains that a standard drink contains 0.6 ounces of alcohol, and explains standard serving sizes for beer, wine and spirits. Anything less would force consumers into “guesswork.”
- “It is without doubt [that this rule] is one of the most significant undertakings by the Bureau in the last 20 years.”
- TTB should provide more flexibility, especially for small containers, to allow the information to be conveyed by a linear format, or an 800 number, or a website.
- TTB should allow a five-year rather than a three-year phase in, due to the scope of this rule.
- A survey of 1,221 adults found that 61% support nutrition labels on beverage alcohol . 69% rated “alcohol content per serving” as most important and 85% consider the definition of a standard drink helpful.
Related Posts:
Tags:
policy, serving facts/allergens
Posted in:
Email This Post
| Print This Post
|
