Vineyard & Winery Management

January/February 2014

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Requiring 'Serving Facts' on Wine Labels Could Prove Costly The potential effects on wineries if TTB proposal becomes mandatory BY TAYLOR N. BURRAS AND JORDAN R. BERNSTEIN ith consumers paying closer attention to food and beverage product labels, government regulatory agencies have felt compelled to consider amending regulations to require inclusion of nutritional information on alcoholic beverage labels. Currently, disclosing nutritional and caloric information on alcoholic beverage labels is voluntary. But if the voluntary disclosure becomes mandatory, wine producers will have to undergo significant changes to their labeling and production processes to comply with the new requirements. TTB RULING 2004-1 In April 2004, the Alcohol and Tobacco Tax and Trade 142 V I N EYA R D & WINE RY M ANAGEM ENT | Jan - Feb 2014 Bureau (TTB) issued Ruling 2004-1, under which alcoholic beverage manufacturers are permitted to include calorie and carbohydrate content information on labels and in advertisements, as long as the nutrient statements are "truthful and do not mislead consumers." The TTB was specifically concerned with the growing use of "low-cal," "low-carb" and similar representations in labeling and advertising, which they determined could mislead consumers to believe that consumption of alcoholic beverages may aid weight loss or weight management. The TTB issued a statement that labels or advertisements will be considered misleading unless accompanied by a "statement of average analysis," w w w. v wm m e d i a . c o m

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