ATB Notice No. 41

The Alcohol and Tobacco Tax and Trade Bureau recently released Notice No. 41 for comment from the industry.  This notice proposed new rules for wine, beer, and spirit labeling.  Under the proposed legislation, alcohol manufacturers would be required to create new labels for their product that describes calories, carbohydrates, fat and protein information for the serving size.  It would also be required to list the amount of alcohol contained in one serving of the beverage, although some states have regulations prohibiting the listing of alcohol on beer.  The proposed labeling is designed to help the consumer, but does it really?  And what affect will it have on the industry?

Nutritional information on alcohol labels

New labels are required by the proposal to contain nutritional information.  Usually alcoholic beverages do not contain any fat.  Some beverages contain small amounts of protein, but the amounts are not likely to be high enough to make much difference.  That leaves calories and carbohydrates.  Beers contain carbohydrates, but wine and spirits contain almost none.  All alcoholic beverages contain calories, but the caloric content is a function of the amount of alcohol in the drink.  Alcohol contains about 7 calories per gram of alcohol.  Simple math can give a very reasonable estimate of caloric content.  Is a new label necessary to convey the number of calories?

And is caloric content an accurate measure?  Some studies show that moderate alcohol consumed with food changes the absorption rate of nutrients. (Lawrence Feinman, Absorption and utilization of nutrients in alcoholism; Alcohol Health & Research World, Summer, 1989, Eric Jequier, Alcohol intake and body weight: a paradox; American Journal of Clinical Nutrition, Vol. 69, No. 2, 173-174, February 1999)  Alcohol increases metabolic rates, and moderate use has even been shown to increase weight loss.  The real problem is that the new rules would require nutritional information on a beverage that has no real nutritional value.

Serving sizes can also be very misleading to a consumer.  A 1.5 oz spirit has much more alcohol than a 5 oz serving of wine or 12 oz serving of beer.  Can they really be considered equivalent?  In Colorado, beer can be purchased that is 3.2% or lower.  If you have 2 beers over a one hour period, is this really the same as 2 shots of tequila?  Listing a serving size on labels could be very misleading and dangerous to a consumer.

Cost for new alcohol labels

Another issue is the cost to the industry.  While large manufacturers would not be hit as hard, smaller wineries and breweries could be hit very hard.  According to the Small Business Association, 98% of America’s wineries are considered small businesses.  Changing a label could cost anywhere from $2000 to $5000 dollars per label design.  This does not include the laboratory costs to analyze the beverages or the proposed allergen tests.  These amounts add up significantly for small producers.

The new proposal does have the consumers’ interests at heart, but the new labeling does not seem well thought out.  Requiring nutritional information on a beverage that contains no nutritional value seems unreasonable and unnecessary.

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