TTB Voluntary Labeling

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In December 2003, CSPI, the National Consumers League, and 67 other organizations sent a petition to the U.S. Alcohol and Tobacco Tax and Trade Bureau (TTB) requesting a new rule to improve mandatory label information on alcoholic beverages.

 

The petition asks TTB to issue a rule that would require labeling of all alcoholic beverages in a standardized format, including:

a.    the beverage's alcohol content expressed as a percentage of volume;

b.    the serving size;

c.     the amount of alcohol per serving;

d.    number of calories per serving;

e.    the ingredients (including additives) from which the beverage is made;

f.     the number of standard drinks per container; and

g.    the U.S. Dietary Guidelines' advice on moderate drinking for men and women.

Since then, while in the process of evaluating the petition, TTB received inquiries from industry members who want to pre-emptively provide voluntary serving facts information on their alcoholic beverages.  TTB seems inclined to grant those requests and solicited limited comment, within a short time-frame, on the content and format of those voluntary labels (see TTB white paper).

CSPI quickly responded to this new round of discussion (see CSPI’s comments), essentially supporting TTB's proposal as a modest positive step toward improved labeling of alcoholic beverages.  Primarily, the new voluntary labeling regime would mandate a consistent “Serving Facts” label format and consistent label contents for those producers who choose to label that information.

Fortunately, the proposed voluntary label will provide some of the information we asked for in our petition: serving size, the amount of alcohol per serving, the number of servings per container, and the number of calories per serving.  In addition, TTB will require language that defines a “Standard Drink,” with easily recognizable drink icons that producers could use if desired.

CSPI’s comments propose a number of improvements, including the increased prominence of alcohol-content information (and the added expression of alcohol content as alcohol by volume) and the need to link the new label with ingredient information, the currently mandated Government Warning, and the Dietary Guidelines’ definition of moderate drinking (see CSPI’s proposed wine label design).  Our major recommendation promotes making such labeling mandatory, to allow consumers to compare among all alcoholic beverages and avoid potential deception.  And, because alcohol is not a food and most alcoholic beverages contain little, if any, fat or protein, those nutrients should not be listed on the new label.  Such information might mislead consumers into thinking that they are important components of alcoholic beverages.

TTB’s proposal suggests that the agency will continue to consider the December 2003 petition;  we hope this voluntary labeling standard won’t derail more meaningful labeling change.

Prior to submitting our comments to the TTB, we surveyed CSPI's “Action Alert” subscribers.  In two days, roughly 1200 subscribers (980 who currently drink) responded, and a majority support mandatory labeling, ingredient labeling, and would prefer a labeled beverage to an unlabeled one.  The results of the survey are available here.

If you would like to start participating in our surveys, please click here, and select “Alcoholic Beverages.”

August 2004

For more information, please send us an email.

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Center for Science in the Public Interest

Alcohol Policies Project

1220 L St NW, Suite 300

Washington, DC  20005

Phone: 202-332-9110 * Fax: 202-265-4954 * Web: www.cspinet.org/booze