WineAmerica Files Positions on Possible Labeling Changes
While Congress is in its long August recess, there’s still work to be done in DC on the regulatory front. Executive Vice President and Director of Regulatory Affairs Michael Kaiser submitted two long, detailed documents to the federal Tax and Trade Bureau (TTB) about the possible addition of information on wine labels.
Specifically, the two issues involved the possibility of “Alcohol Facts” statements on the labeling of wine, spirits and beer; and the possibility of “Major Food Allergen” labeling. WineAmerica’s overall position: “WineAmerica is in favor of both allergen and ingredient disclosure, as long as it is done in a way that is not harmful to the American wine industry. Only agents that are detectable in the finished product should need to be disclosed by a producer. Additionally, as we stated in our comments for Notice 237, an off-label, web-based disclosure is the best option for the wine industry. This is already occurring in the European Union and should naturally be an option for our producers.
WineAmerica also made clear that in the first instance, the information should be described as “SERVING FACTS” rather than “ALCOHOL FACTS” to avoid confusion. In addition, WineAmerica urged TTB “to bear in mind that the 10,000+ American wineries are predominantly small family farms with very limited resources, and that $1600 per label and $500 per product test would be a major financial burden.”
At the same time, FIVS, the global voice of the wine sector, filed similar comments on behalf of the international wine community. FIVS is essentially an international version of WineAmerica, with wine producers and associations from around the world tracking developments on a global level. WineAmerica has always been a strong supporter of FIVS, and its current co-president is Charles Jefferson, vice president of government affairs at Wine Institute.
Julie Hesketh-Laird, CEO of FIVS, said, “Wine labeling rules must adapt to the expectations of today’s consumers and the realities of a modern, digital economy. E-labeling offers a smarter, more flexible way to provide accurate, relevant information, while opening new opportunities for international trade and engagement. This approach creates shared value for consumers, producers, retailers, and regulators.” For FIVS “Good Regulatory Practices for Electronic Labeling, visit https://grco.de/FIVSPrinciples
By last Friday’s deadline, the TTB had received about 13,000 comments from various sources. While these are potentially important issues for the wine industry, we do not expect any significant action in the foreseeable future, and we will keep WineAmerica members fully updated. Any member who wants a copy of the filings may contact Michael Kaiser (mkaiser@nullwineamerica.org). They are 4, and 9, pages respectively.