Experienced And Knowledgeable With Both The Alcohol beverage Industry And The Law

Virtual Public Listening Sessions on Labeling and Advertising of Wine, Distilled Spirits, and Malt Beverages with Alcohol Content, Nutritional Information, Major Food Allergens, and Ingredients

On Behalf of | Apr 12, 2024 | Firm News

In late February, TTB held virtual listening sessions to receive input from the public on labeling of wine, distilled spirits, and malt beverages, and invited industry members to speak. Below is a summary of some of the speakers and their suggestions.

  • General Counsel of the Brewers Association (Mark Sorini): emphasized how important it is for brands to be transparent in the labeling process, ultimately supporting the on-label disclosure of ingredients, allergens, alcohol content, and nutritional information. Ultimately, recommending adding QR codes to the labels in order to minimize costs on smaller businesses. However, he also advocated for flexibility with the standards and a grace period for implementation if the ruling is established in order to have time to make the proper adjustments to be compliant.
  • Director of compliance for an importer company in California (Hugo Prochasson): stated that small businesses will benefit from adding QR codes to their labels similar to EU countries, ultimately minimizing the burden for small producers. By doing this, it would avoid the process of reapplying for a COLA which would be a hassle for the industry.
  • Operations manager at St. George Spirits (Lucy Farber): emphasizes the difficulties craft distillers face when it comes to nutritional labeling, specifically highling the costs and logistics that are required for testing and redesigning labels. Leading her to ultimately advocate for QR codes similar to those in the EU.
  • Distilled Spirits Council of the United States (Courtney Armour): believes that it is important for regulations to meet consumer demands but these regulations should be set without causing a burden to distillers. She emphasizes that there are alot of hoops that are already set in place for spirits, leading her to advocate for flexibility when it comes to these potential regulations. She states that allowing qr codes or website references can help create a balance to support consumer access without becoming a burden to distillers.
  • Mawby Sparkling Wines (Peter Laing): supports the consideration of having the nutritional information off the label as the previous commentators suggested. He also suggests that only the ingredients present in the finished product should be required to be listed on the label. Ultimately echoing what the previous speakers had stated in the burden that this regulation would potentially be to small businesses.
  • Vice President of Federal and International Policy at Wine Institute (Charles Jefferson): advocates for the proposed off-label disclosure as well, specifically QR codes or any electronic means in order to accommodate the diversity of wine products. He also emphasizes the importance of being allowed sufficient time in order to implement the new regulations.
  • Katrina Brewing Co. (Godfredy Salazar): this speaker emphasized the inconsistencies that there is with the labeling requirements. Ultimately, pushing for updates in the regulations in order to avoid this issue. He also proposes the option to be able to categorize non-alcoholic beers as lagers. Due to the fact that non-alcoholic beers aren’t allowed to be classed as “lager” as of now. And lastly, he suggested including pasteurized in non-alcoholic beers.
  • Private consultant with Proper Pour Co. (Jemma Jorel Lester): This speaker particularly speaks about the challenges in compliance that hospitality companies face. She brings up the fact that when multiple labels are submitted for approval they are sent to various people within the TTB, she brings up that this causes companies to get varied responses even on a consistent set of labels. This leads her to suggest that there should be more regulations set in place in order to avoid these different responses or just have one person assigned in order to have consistent feedback. She also suggests that the TTB should update their website in order to
  • Executive Vice President of Wine America (Michael Kaiser): advocated for off-label disclosure due to the fact that this regulation would be a burden to small businesses. He also asks for the TTB to take into consideration the financial burden this will be to small businesses, and ultimately suggests the TTB to offer specific tolerances in order to alleviate.
  • President of the National Association of Beverage Importers in Washington DC. (Robert Tobiassen): pointed out that there needs to be uniformity, and consistency in the global marketplace. He also said that the TTB should not impose our labeling regimes onto consumers in other countries. He believes that the use of stickers should be allowed in order to avoid the cost of reprinting labels. He even extends to suggesting consumer surveys.

Recent Posts


About the Blog

The foregoing was prepared as general information. It is not meant to provide legal advice granting any specific matter and should not be acted upon without professional counsel. If you have questions or require additional information regarding these or other related matters, please contact Malkin Law, P.A. This material may be considered attorney advertising under certain rules of professional conduct.