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.
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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?
Barleywine; Is it Beer, Wine or Both?
Beeradvocate shows over 400 barleywines, from the US alone. Because this type is common, but not nearly so well known as stout or rum, for example, we wanted to take a closer look. Beeradvocate says:
Despite its name, a Barleywine (or Barley Wine) is very much a beer, albeit a very strong and often intense beer! In fact, it’s one of the strongest of the beer styles. Lively and fruity, sometimes sweet, sometimes bittersweet, but always alcoholic. … English varieties are quite different from the American efforts, what sets them apart is usually the American versions are insanely hopped to make for a more bitter and hop flavored brew, typically using American high alpha oil hops. English versions tend to be more rounded and balanced between malt and hops, with a slightly lower alcohol content, though this is not always the case. … Most Barleywines can be cellared for years and typically age like wine. … Average alcohol by volume (abv) range: 8.0-15.0%.
Wikipedia provides additional details : “In the United States, barley wines are required … to be called ‘barley wine-style ales.’ Though this could be taken by some to imply that they are not truly barley wines, in fact it only means that they, like all barley wines, are not truly wines.” Bass was first, around 1900, and the term stems from the fact that many barleywines have an alcohol content similar to that for wine.
The above label nicely demonstrates the US “requirement” to add “Style Ale.” Based on this TTB definition for “wine,” we don’t see why it’s so obviously beer rather than wine: “When used without qualification, the term includes every kind (class and type) of product produced on bonded wine premises from grapes, other fruit (including berries), or other suitable agricultural products and containing not more than 24 percent of alcohol by volume. The term includes all imitation, other than standard, or artificial wine and compounds sold as wine.” We do acknowledge, however, that this definition (for “malt beverage”) probably fits better.
DISCUS Comment; Top 6 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 13 in a series; to see others, click on the “serving facts” tag below.
The Distilled Spirits Council of the US (DISCUS) is a trade association representing spirits producers and marketers. DISCUS submitted a 14-page comment, plus 6 pages of footnotes and a 61-page survey making these points:
- Some DISCUS members market wine and beer, so DISCUS has a broad perspective.
- DISCUS opposes the proposed Serving Facts panel, whether required or optional. It will not provide sufficient information unless it explains that a standard drink contains 0.6 ounces of alcohol, and explains standard serving sizes for beer, wine and spirits. Anything less would force consumers into “guesswork.”
- “It is without doubt [that this rule] is one of the most significant undertakings by the Bureau in the last 20 years.”
- TTB should provide more flexibility, especially for small containers, to allow the information to be conveyed by a linear format, or an 800 number, or a website.
- TTB should allow a five-year rather than a three-year phase in, due to the scope of this rule.
- A survey of 1,221 adults found that 61% support nutrition labels on beverage alcohol . 69% rated “alcohol content per serving” as most important and 85% consider the definition of a standard drink helpful.
Erythritol in Slender Wine
FDA said Truvia looks okay on December 17, 2008 and TTB approved this wine, with erythritol, a mere two days later. It is difficult to distinguish among erythritol, stevia, Truvia, rebiana and many other new sweeteners hitting the market. Erythritol seems to be a component of Truvia. Fooducate says erythritol is:
a sugar alcohol, a carbohydrate found naturally in various fruits and vegetables. Used in both Purevia and Truvia. It helps them mimic the texture and mouthfeel of table sugar.
Rebiana is:
the trade name for a stevia-derived sweetener developed jointly by the Coca Cola Company and Cargill. According to Cargill, rebiana is “the best tasting part of the stevia leaf.”
Truvia is:
Cargill’s consumer brand of Rebiana-based sweetener packs.
And Stevia is:
a South American Plant from the sunflower family, grown and used by locals for its sweet tasting leaves. Stevia Extracts are 200-300 times sweeter than sugar, but contain no carbohydrates (calories).
Cargill, finally, on its Truvia FAQ explains that erythritol “is a sugar alcohol, a carbohydrate found naturally in several fruits. Erythritol doesn’t lead to tooth decay, is safe for people with diabetes and in reasonable amounts does not lead to gastrointestinal side effects (in other words, no gas or bloating).”
Beer with Vitamins
TTB is unlikely to allow “Beer with Vitamins” anytime soon. And yet every couple of months, we hear a report of another “beer with vitamins.” Most often, it’s based on flimsy evidence. But every now and then, something very close or on the mark will turn up.
Stampede Light (above) shows a beer sometimes purported to contain vitamins. The approved labels don’t mention vitamins. But the advertising strongly hints that this beer contains added vitamins. The website (as of March 2009) refers to doctors, vitamins, health, and shows a person doing one-handed pushups. It probably went much further, before 2007. Forbes reports that Larry Schwartz:
launched Stampede in November 2005 by marketing it as “beer with horsepower” and trumpeting its added vitamins in print ads and radio spots in Texas–and on his MySpace page. A short time later he received a letter from the Alcohol & Tobacco Tax & Trade Bureau, part of the U.S. Treasury Department. The TTB says health-related claims made by alcoholic drink manufacturers must be verifiable and balanced with revelations about the health risks of excessive alcohol consumption.
Schwartz … who has racked up $100,000 in legal fees while negotiating with the TTB, hopes below-the-radar marketing tricks will give Stampede a boost–and keep him out of trouble.
For example, it looks as if Mr. Schwartz has retained a certain actress to say what he’d better not say.
We did find another brand — with clear evidence of added vitamins, right on the approved front labels. But before setting off any more false alarms about beer with vitamins, we hasten to add that these approvals are not recent, and their current status is “surrendered.”
TTB is at the early stages of developing regulations related to alcohol beverages containing vitamins, minerals and caffeine.
March 19, 2013 Update: TTB’s interim policy.
