policy

This may look like just another ready-to-drink spirit but there is quite a lot going on here.

1. It is two products on one label approval form. Box 19 (of the approval linked above) carefully notes “there are two pre-import letters associated with this product.”
2. It is important to sell these in a four-pack because each cup is only 25 ml. TTB does not allow 25 ml. for spirits. When four are joined together, as here, it conforms to the 100 ml. “standard of fill.” These standard of fill rules have been important to TTB for many decades. TTB calls this aggregate packaging.
3. To reinforce the aggregation, it is helpful to say NOT FOR INDIVIDUAL SALE.
4. Because they are tiny, it is helpful to state NOT FOR CHILDREN. This can help avoid the shame of a Liquid Lunchables designation.
5. It is important to put some labeling on the outer pack and some on the inner pack.

The origin (New Zealand) is also a bit unusual for spirits. There are a great many products in the Twistee Shots line, imported by Smart Beverage of Louisville, Kentucky.

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 5 in a series; to see others, click on the “serving facts” tag below.

1. Diageo said milk, soda and most other beverages sold in the US include nutritional information “Yet, anomalously and without any good justification, this same information may not be included on the labels of alcoholic beverages.”
2. TTB cannot constitutionally forbid nutritional information while it completes its lengthy rulemaking process. The information is simple, factual, truthful, non-misleading and “the First Amendment does not countenance this form of information suppression.”
3. The government bears the burden of demonstrating that...

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 4 in a series; to see others, click on the “serving facts” tag below.

1. WineAmerica said “This rulemaking could lead to one of the most far-reaching revisions of wine label requirements … in the history of wine in America.”
2. Most common wines “fit into a very narrow band of calorie content per serving, about 120 calories” and this information is easy to find on the Internet. The rule could cause “information overload” and would provide “very little, if any benefit” to consumers.
3. These changes would have “very negative economic effects” on more than...