This week the Alcohol and Tobacco Tax and Trade Bureau, known as the TTB, published notice 232, asking for public comment on the proposition to add mandatory ingredient, allergen, and nutritional labeling information to wine and spirits.
Here is the comment that I submitted today to the TTB :
I am writing both as a consumer and as a someone who has worked as a professional wine writer for the last 20 years. I am pleased to voice support for the idea of ingredient, allergen, and nutritional labeling for wine and spirits.
A great deal of confusion and misunderstanding exists for consumers about alcoholic drinks in general, and wine in particular. Consumers currently make decisions about what to drink based on faulty assumptions and misinformation. Whether it is calorie count, presumed additives, or sugar levels, the inability to know for sure what is in the alcoholic beverage being consumed means that consumers cannot make fully informed choices based on their goals and preferences for their health, diet, and well-being, something they have become used to doing with all other FDA-regulated food and drink.
I believe that consumers need and want the following information about their alcoholic beverages:
- Recommended serving size / servings per container
- Calories, total carbohydrates, total residual sugars, and sodium per serving for all beverages
- Protein and total fat for beverages that have them
- Whether the beverage contains* any known allergens and what those allergens are
- Ingredients and additives that effectively remain in significant amounts* in the final product
* The TTB must establish a clear rule, aligned with FDA standards, for what distinguishes an ingredient from a processing aid and what level of presence in the final product merits a disclosure. There are many substances used in the making of wine and spirits that, while they come in contact with the product during its manufacture, effectively do not remain in the final product, including but not limited to filtering and fining agents, yeasts and yeast nutrients, aging containers such as wood, etc. Alcohol producers need VERY CLEAR guidance as to what they are required to disclose in labeling.
Wine, as a particular category of alcoholic beverage, has a specific method of manufacture, and wine consumers care about the details of how the product was made, especially for the purposes of distinguishing between artisan, hand-made products and those made using more industrial methods. (This may also be true for other alcohol categories as well, but that is outside my specific personal knowledge). To this end, I believe many wine consumers would like the following disclosures about the following potential ingredients/additives/processing aids that are used in winemaking, notwithstanding the caveat above about what actually should constitute an “ingredient”:
- Added yeasts
- Added yeast nutrients and enzymes
- Dimethyldicarbonate, ammonium phosphate and diammonium phosphates
- Added grape concentrate
- Coloring agents or color stabilizers of various kinds
- Acid, sugar, or tannin additions
- De-acidification additions such as potassium bicarbonate or calcium carbonate
- Stabilizers and anti-sediment additions such as potassium bitartrate or urease
- Fining agents that have allergen or philosophical/dietary impacts (egg whites, soy flour casein, isinglass, etc.)
- Sulfur dioxide
- Preservatives or antibacterial agents such as potassium sorbate, dimethyl dicarbonate, sorbic acid, copper sulfate
- Added alcohol (for fortification)
- Oak and cork chips, powders, and granules
- Other flavoring agents remaining in trace amounts in the finished wine including botanicals, fruits, etc.
Some of these items either break down or are/can be removed during the winemaking process. Yeasts, for instance, may be filtered out of the final product or, if the wine is unfiltered, they may remain. Fining agents that may in themselves…
Source : https://www.vinography.com/2024/02/why-i-support-ingredient-labeling-for-wine