Comment 0419999

From: Zakgroves@aol.com
Sent: Wednesday, August 17, 2005 8:31 PM
To: Rulemaking, TTB
Subject: 'TTB Notice No. 41'

Thank you for the opportunity to comment on possible changes to the labeling and advertising requirements of alcohol beverage products. Following are my responses to some of the general questions being posed by the TTB:

  1.. Yes, TTB should seek to require mandatory nutrition labeling for alcohol beverage products, or at the very least information about calorie content. At a time when so many health experts are expressing concern over obesity, and at a time when FDA is considering making calorie content information more prominent on food labels, it seems to me that the TTB should make calorie content information mandatory on all alcohol beverage products. 
  2.. Yes, TTB should seek to require mandatory ingredient labeling. This is required for almost all food and beverage products; I dont know why it isnt also required of alcoholic beverages. 
  3.. Cost of implementing these potential new requirements perhaps needs further study. Im thinking particularly of small brewers who brew seasonal beers; costs of analyzing these products and making new labels would likely be pretty high, so perhaps there could be a longer phase-in period for mandatory nutrition and ingredient labeling (based on sales or production volume), or perhaps instead of mandatory labeling of these products, brewers of small volume beers could be required to post nutrition and ingredient information on their websites, thereby eliminating the cost of printing new labels.
6. I believe consumers would derive significant benefits from more specific information on alcohol beverage labels, including information about nutrition content and ingredients as well as alcohol content. Yes, these benefits are sufficient to warrant the economic costs associated with these revisions. The food industry went through this process following passage of the Nutrition Labeling and Education Act of 1990; as a consumer, Im not completely happy with information currently required on the Nutrition Facts panel (for example, Calories from Fat is in my opinion unnecessary, and Trans Fat information should have been made mandatory years ago), but it certainly beats what was available 15 years ago. And the food industry seemed to absorb most of the costs associated with these labeling changes without these costs being passed on to consumers.

7. The agencys priorities should be as follows: alcohol content, nutrition labeling, and then ingredient information.

8. Yes, if TTB requires, for example, calorie content labeling, it should also define such terms as reduced calorie as used both on labels and in advertising. 



Dick Groves

Poynette, WI