Bob Skilnik does a good job covering the serving facts issue, as to alcohol beverages, and we must admit we got this idea from his recent post here. The above video shows former Surgeon General C. Everett Koop extolling the need for adding serving facts information to beer, wine and spirits labels without further ado. We wanted to highlight this video because it seems quite effective, whether you agree or disagree. That is, we think it is effective especially when compared to many of the written comments submitted to TTB over the past few years. We have summarized many of the written comments on this blog; some are quite persuasive and a great many are, shall we say, lame. We find it particularly lame to assert, for example, everybody knows that beer has no fat, so it’s a waste to force beer companies to declare it. The same could be said about alcohol content. Everybody knows beer is about 3-5% alcohol by volume. Except when it isn’t. Maybe it happens to be 13.4% alc./vol. or 21% alc./vol. or 2.16% alc./vol. Where is the harm in telling consumers, simply and directly, that Guinness Stout has no fat, just like a low carb beer or a sugared-up flavored malt beverage?
Yes; it will be expensive and cumbersome to add serving facts information to hundreds of thousands of alcohol beverage products, but it’s too easy to say nobody cares, or consumers already know. In a few days, we plan to summarize Dr. Koop’s written comment on the same topic.
The second reason we wanted to highlight this particular video clip is that it seems to have only 232 views in YouTube as of this writing. Again, whether you agree or disagree, we thought it’s a good issue that should have more viewings.
Dr. Koop is Serious About Beer and Fat
About Author
Robert C. Lehrman is the principal attorney at Lehrman Beverage Law, PLLC. Robert founded the firm in 2001 after 12 years at the Washington, DC office of a larger firm that specializes in federal and state administrative law. From 1998...... Read Full Bio
My experience so far with the TTB and the inevitability of a nutritional analysis statement on alcoholic products is that consumers, naturally, are for it. The vintners and brewers, especially the smaller operations, are dead-set against it. Their argument is cost-based, and while I understand that no one needs added costs to be added to any drink operation, I see small food operations accepting a nutritional analysis statement plus a listing of ingredients on their products as an assumed operating cost. If the ma-and-pa cookie company has to submit their products for lab analysis and provide this info to their customers, why not drink manufacturers too?
Vintners and brewers, however, like to bring up the health-related arguments of why their products are “good” for consumers (resveratrol, phenols, flavonoids, vitamin B compounds, etc.) and yet avoid any attempt to get them to add nutritional info on their products, or simply their websites or POP materials.
You can’t have it both ways.
I will admit, however, that some regional brewers who refused to provide me with any nutritional information about their products just a few year ago when I wrote my first book on beer and nutrition, have seen the light and are now quite cooperative in providing info about their products.
You can’t fight the feds nor the wants of the marketplace. Consumers want nutritional information on their favorite beer, wines and distilled products. Those who provide this info will be the ones who will win in sales.
Bob, the pro-extra labeling forces submitted a lot of surveys to TTB. I would love to see just one that asks:
1. Would you like to see basic nutritional information on alcohol beverages?
2. Would you be willing to pay 5% more to cover it?
At least to me, that would be telling. Offering 1 without 2 is like asking a kid, “do you want free candy?”
I’m curious… Why wouldn’t sugar content be listed as well?
Japhet, it seems like a good question. I don’t have a good answer. There is lots of sugar added to many spirits products, and I suppose many consumers want and need to know how much. By law liqueur must have at least 2.5% sugar by weight, but that doesn’t help with whether a given product is closer to 2.5% or 15 times that. Many flavored malt beverages also have a lot of added sugar. (Just the other night I was wondering if my absinthe had any sugar.) Maybe Bob Skilnik (http://drinkhealthydrinksmart.com/) has a good feel for this. So far as I recall, few if any of the many thousand comments have called upon TTB to show this information. Do you think it should be listed? Why?
Sugar is represented as calories and/or carbohydrates. There has to be a line drawn somewhere, otherwise the only thing a label will fit on would be a 750 ml. one. Right now, especially with heat coming from the Center for Science in the Public Interest (CSPI) and the EU, the TTB is also weighing adding allergens and ingredients to labels.
Then you come to additives used during the production process, the polymer polyvinylpolypyrrolidone (PPVP) for beer filtering, for instance. If it’s added to beer to aid filtration and then removed during filtration, should it be included as an “ingredient” in beer?
To get the latest feel for what’s on the minds of the folks at TTB on the labeling issue, go to ttb.gov and do a search for “27 CFR Parts 4, 5, 7, and 24 Labeling and Advertising of Wines, Distilled Spirits and Malt Beverages; Proposed Rule.” This comes out of the Federal Register, dated July 31, 2007. It’s about 24 pages long but it does answer a lot of questions and addresses some “what if’s?” too.
As for the cost issue — very much on the minds of smaller wine and beer operations…pages 41871, 41872 and 41873 directly address this. It’s too lengthy to go into here, but the TTB does propose a 3-year implementation of any label changes. They also are relying on an analysis made by the FDA, titled “FDA Labeling Cost Model Final Report” (revised January 2003) that attempts to soften the economic blow of labeling changes and associated costs.
With most soft drinks, sugar is listed under Total Carbohydrates. I tend to avoid drinks, alcoholic and otherwise, with a lot of sugar and despite the lack of comments addressing this on the forum, I would guess that many consumers, especially diabetics, would appreciate knowing how much sugar is in the products they buy.
I don’t know of any research to back this up but I’d love to see a survey done on this.
As for drawing a line, I was under the impression that the industry was going to be given some leeway as to the size of the table. Smaller type might be harder to read but having some experience with graphic design, I’d be surprised if they couldn’t make it work somehow.
I don’t know about allergens (we have designated gluten-free beer; are there are other allergies I don’t know about?) but I would like to see a full list of ingredients. I’m a big fan of organic beer and wine that doesn’t contain sulfites and while that information is included on many bottles, I’d like to see it all put in one place for easy viewing.
The additives definitely seem like a good place to draw the line. If it’s removed during filtration, I would argue that while its part of the process it’s hardly an ingredient.
The TTB currently has defined font sizes for label text. If they revise this and allow for a smaller size, someone will moan that it’s an attempt to hide info.This is the kind of stuff that TTB is trying to work with.
As for diabetics…I work indirectly with some health advocacy groups, especially diabetes organizations, and they are chiefly concerned with carbohydrate counts in food and drink. Menus and daily food allowances for diabetics are all based around carbohydrates, not sugar. Controlling carbohydrates reflects the process of eating, the release of glucose and the subsequent dumping (or lack of) of insulin to temper this.
Allergens? Think peanuts, sulfites, artificial sweeteners, even dairy products.
I didn’t know that, thanks for sharing.
Bob, I don’t know about that. I talked with an MD and a diabetic today. They both said diabetics are intensely interested in the sugar content of every food. Can you find a medical professional to weigh in on this? I think Japhet raises a good point.