February 20, 1998

Mr. John W. Magaw
Director
Bureau of Alcohol, Tobacco, and Firearms
Department of the Treasury
650 Massachusetts Avenue, N.W.
Washington, D.C. 20226

Re: Wine Health Claims

Dear Mr. Magaw:

I am writing to reiterate CSPI's continued opposition to BATF's potential approval of proposed label statements concerning the health effects of moderate wine consumption. Our position on the proposed labels has not changed, despite the findings of a recent preliminary study by the Substance Abuse and Mental Health Services Administration of the Department of Health and Human Services and inaccurate statements by the California Wine Institute.

A report on alcohol consumption and the risk of breast cancer in this week's edition of the Journal of the American Medical Association provides additional cause to reject wine label language that might promote alcohol consumption. That study by researchers at the Harvard School of Public Health confirms numerous earlier scientific reports that linked alcohol consumption to breast cancer. It found that alcohol consumption, even at levels of less than one drink per day, may increase the risk of breast cancer.

Currently, labels for alcoholic beverages do not provide a warning of the breast-cancer risk. Nor does the Dietary Guidelines for Americans, to which the Wine Institute's proposed health-claim label message would refer consumers. The Guidelines' silence on the risk of breast cancer at moderate levels of alcohol consumption supplies another example of how the proposed label has the tendency to mislead consumers and how it would provide incomplete and unbalanced information about health concerns related to drinking.

Several of the findings of the SAMHSA study also strengthen our concerns about the public health and public policy implications of BATF approval of the wine industry's proposed labels. The study surveyed only current drinkers, most of whom drank wine. It failed to provide any indication of how non-drinkers and underage persons might respond to the label or to the anticipated ancillary media coverage of the health benefits of alcohol consumption.

The study also found that the concept of "moderation," a key ingredient of the proposed labels, is meaningless. It varies widely from a couple of drinks per month to more than six drinks per day. Heavier drinkers consistently had higher estimations of "moderate" drinking, ostensibly to rationalize their own excessive alcohol consumption or deny that they might have a drinking problem. Those responses would be expected from people who may be in trouble with alcohol. One-third of the heavy drinkers in the sample considered wine "very healthy." Wine label information that may perpetuate these beliefs can only be considered inimical to public health.

BATF should not rely on the SAMHSA study to support approval of the wine industry's proposed labels about the health effects of moderate wine consumption. Approval of those labels, even if they were to direct a few consumers to the U.S. Dietary Guidelines for more information, would nonetheless provide incomplete, unbalanced, and potentially misleading guidance to the public about important health effects of alcohol consumption.

We encourage you to reject the proposed labels. We urge you to work more closely with the Department of Health and Human Services to develop informational tools that would provide a balance of information on alcohol and health, without permitting the wine industry to promote its products as health foods.

Sincerely,

George A. Hacker
Director
Alcohol Policies Project

To read the accompanying press release, click here .

To read the JAMA abstract, click here .