The ongoing labeling debate

Wines & Vines,  May, 2006  by Elisabeth Holmgren

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During the last few years, nutrition and ingredient labeling issues with respect to alcohol have been in the forefront of an ongoing public health movement. Consumer advocacy and public health groups have taken the lead in supporting more detailed label information by petitioning the Alcohol and Tobacco Tax and Trade Bureau (TTB).

The debate led the TTB to issue an Advanced Notice of Proposed Rule-making (ANPRM) seeking public comments on several issues to assist the agency in formulating specific regulatory proposals. ANPRM Notice No.41, Labeling and Advertising of Wines, Distilled Spirits and Malt Beverages, raises many issues and questions about nutrition labeling, ingredient and allergen labeling, drinks comparison graphics and alcohol facts labeling.

Responses from groups such as the Center for Science in the Public Interest and thousands of consumers who responded as part of a digital grassroots effort, call for more mandatory label information. In contrast, others, and specifically industry associations, have presented in-depth arguments questioning the value of such proposals, which would affect the wine industry and its members in many fundamental ways.

The central question is whether any more detailed label information would be of true value for the consumer, considering its overall educational impact and costs for wineries. To date, the TTB has not announced any subsequent steps in the review process. This article is intended to provide an overview of the TTB's key questions and overall wine industry responses.

Should Listing Of Nutrients And Calories Be Required?

The issue at hand is whether the TTB should require mandatory nutrition labeling--with respect to calories, fat, carbohydrates and protein--or should such information be permitted on a voluntary basis. Industry associations oppose mandatory nutrition labeling on wine. They argue that more information could confuse and mislead consumers, and even detract from other, more important label information, such as the on-product warning label.

Nutritional analysis has revealed that wine does not contain fats or proteins and is almost carbohydrate-free.

Therefore, the caloric content of wine is normally derived from a simple relationship with the wine's alcohol content, a listing already required within fairly narrow ranges. Furthermore, it has been argued that the listing of alcohol calories is misleading and unwarranted, as emerging medical evidence indicates that consumption of alcohol is not associated with weight gain and may even be linked with weight loss.

In addition, it has to be considered that wine is a complex beverage, with minute amounts of macronutrients but small and potentially nutritionally significant amounts of certain vitamins, minerals and antioxidants that research studies have associated with lifestyle advantages.

Looking at all this data, it becomes apparent that nutrition labeling could not accurately convey wine's complexity and unique metabolic contributions as part of a well balanced diet and lifestyle. Industry organizations hope that the TTB will consider its earlier conclusions with respect to labeling, which have always emphasized that labels may not contain any wording that is untrue in any particular or tends to create a misleading impression as to the effects of alcohol consumption. In fact, in 1993 the TTB (then BATF) published an earlier ANPRM to consider whether nutrition labeling information should be required. This was turned down, as its importance to consumers was questioned.

With respect to the overall effectiveness of labels, it has also been suggested that the TTB consult with the Food and Drug Administration (FDA) and consider studies which have found that the number of consumers using nutrition panel information on labels has not increased since the 1990 Nutrition Labeling and Information Act.

Should Listing Of Ingredients and Processing Aids Be Required?

It has been proposed that the TTB require mandatory ingredient labeling or allow voluntary ingredient labeling listing of all ingredients used to make the product, including processing aids. The industry has long opposed such proposals, arguing that such labeling would not deliver useful information to consumers.

In fact, there is no clear need for such information on wine, as current TTB regulations include very tightly drawn standards of identity and limitations on additives that ensure that standard wines are basically direct products of fruit, and as such are sufficiently described to the consumer. This issue was reviewed by the agency before, and during the 1970s and 1980s it was determined that ingredient labeling should not be required, as it would be of little value or even confuse the consumer. The agency based its conclusion on an in-depth review, which explained a rather strained relationship between the initial ingredients that go into the production process and the ultimate contents of the product.

Furthermore, in 2003 the USDA's National Organic Program regulations also concluded that ingredient labeling would be inappropriate for alcohol beverages, and eliminated any such requirement.