In recent days a few industry veterans expressed concern about a new distilled spirits specialty with the flavor of bubble gum. Here are two. The newer one is Three Olives Bubble. The label and website don’t mention gum, but this blog confirms that it tastes like Bazooka, and the packaging certainly reminds me of bubble gum. The other one is Bubble Gum Liqueur, bottled by M.S. Walker of Somerville, Massachusetts. This one does not eschew the use of the word “gum,” and refers to Bubble Gum at least half a dozen times. It strikes us as reasonable to evaluate whether gum and candy are so irresistible to children that they are inappropriate on alcohol beverage labels or as main flavors. But in the next post we will show that these two products are not so unusual. There are a great many alcohol beverage products referring to candy — even without counting the hundreds or thousands of chocolate products.

It is likely that all beer, wine and spirits labels will change dramatically in the near future. TTB Administrator John Manfreda confirmed this in a recent speech. 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 21 in a series; to see others, click on the “serving facts” tag below. Michael Taylor (on behalf of Diageo) submitted a 4 page comment. It said:

1. Diageo hired Mr. Taylor in 2005 and he’s currently a research professor at George Washington University. From 1991-1994 he was FDA’s Deputy Commissioner for Policy and was actively involved in setting the comparable rules for foods more generally.
2. I am disappointed that TTB will not require reference to a “standard drink.”
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TTB does not usually allow vintage-, varietal- or appellation-type claims on distilled spirits labels. The rationale is that these concepts tend to be more appropriate for wine. But here are a couple of notable exceptions. Roth Vodka displays “California” in much the manner of an appellation. This vodka also happens to be distilled from grapes, and has something close to a vintage date on the front label. The latter apparently went too far, and TTB directed Roth to remove the date. In some ways, the Primo Vodka label goes a bit further. It mentions a specific grape type, along with the source of those grapes. One side tends to argue that these claims are truthful and verifiable. TTB tends to argue that characteristics such as vintage, varietal and appellation are subtle to begin with; distillation (let alone distillation to the point of neutrality) tends to obliterate such characteristics; and it’s misleading to suggest otherwise. Do consumers need this protection?