Cave Creek Chili Beer (above) is made with a “chili pepper added.” Near as we can tell, the Kansas Hot Pepper Wine is made mainly or solely from hot peppers. The labeling tends to suggest it’s fermented from peppers. But the form tends to suggest it is flavored grape wine (and this seems a bit more likely).
Cave Creek is made in Mexico and imported by Alta Marketing of Redlands, California. Hot Cha Cha is produced and bottled by Dozier Vineyard & Winery of Ellinwood, Kansas.
No Fault Wine
We thought this was a little different, and amusing. His Fault white wine (above), says, on the back:
Did the earth move for you? It’s his fault. … Craving a lush, juicy white blend, with a knockout structure and frisky finish? Now that’s really His Fault.
Her Fault red wine, on the back, says:
Did the earth move for you? It’s her fault. … Craving a sumptuous, deeply flavored blend, with a supple mouthfeel and a really long finish? Now that’s really Her Fault.
The wines are bottled by Adler Fels Winery of Santa Rosa, California.
This Design Lingers
We have giant stacks of shocking and outrageous labels, and yet we keep coming back to this one. It is simple, calm, soothing, and far from outrageous. We are no experts in graphics or design, but we think this is probably the result of superior design. For the best in consumer products design and packaging, we defer to The Dieline; they do a great job covering beer, wine and spirits design issues. Another tremendous source of information about wine label design is Mike Carter’s Serious About Wine. We wonder if Mike, or The Dieline, or anyone else out there can help us narrow down who are the best alcohol beverage label designers around these days.
As the back label says, “it lingers.”
The Prominence of Vodka
TTB often says the term “vodka” may not appear, in a prominent manner, unless: the product is simple vodka, or qualifying language surrounds the term, in the same font. An example is VODKA WITH NATURAL FLAVOR, where TTB would not usually allow VODKA to be more prominent than WITH NATURAL FLAVOR.
The product above is not plain vodka, and yet the term “vodka” appears in a surprisingly emphasized manner. It is emphasized by being large (about five times the size of the actual statement of composition). It is emphasized by repetition (no less than six appearances). It is also emphasized to the extent that “Smirnoff” is or was synonymous with “vodka.” The true statement of composition is hard to read on this scan and says: “MADE WITH VODKA, GUARANA EXTRACT, NATURAL FLAVORS, CARAMEL COLOR, CAFFEINE & SODA WATER.” The other color is off to the side.
TTB has underscored this vodka rule by asserting, on other approvals for this brand: “When new labels are printed, the word ‘vodka’ cannot appear more prominent nor stand alone. [Vodka & Guarana] must appear together and in the same size type print/font.” TTB felt strongly enough to allow it with all of the following restrictions: Arizona sales only, test marketing only, 23,000 cases only, and six months only. Curiously, TTB also said “When new labels are printed, all references to ‘soda’ must be removed.” TTB appears to be concerned that an errant minor could mistake the above (or other alcohol beverages bearing the term “soda”) for a soft drink.
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?