Attn: Director, Regulations and Rulings Division

Alcohol and Tobacco Tax and Trade Bureau

U.S. Department of the Treasury

PO BOX 14412

Washington, DC 20044-4412

Re: Notice No. 73, Docket No. TTB-2007-0062, "Labeling and Advertising
of Wines, Distilled Spirits and Malt Beverages"

Dear Alcohol and Tobacco Tax and Trade Bureau:

I would like to comment on the proposed mandatory "Serving Facts" label
for alcoholic beverages. I do not believe that the inclusion of a
"Serving Facts" label will benefit the consumer enough to justify the
financial impact on small brewers, wineries, and distilleries. The costs
associated with complying with this rule could further diminish consumer
choice by discouraging the production of small batches of wines,
distilled spirits, and malted beverages. Each of these batches would
have to be chemically tested and new labels would need to be designed,
approved, and printed which is a timely and expensive process. This type
of regulatory proposal is unduly burdensome on small producers.
Furthermore, the inclusion of a "Serving Facts" label will take up
valuable real estate on the product that is often used to convey
information that is of value to the consumer including the mandatory
"Government Warning."

The Alcohol and Tobacco Tax and Trade Bureau (TTB) states that it
believes that "that the calorie and nutrient content of alcohol
beverages may constitute important information for consumers interested
in monitoring their overall intake of calories, carbohydrates, protein,
and/or fat." Wines and distilled spirits are not the types of products
purchased with much consideration, if any at all, as to their
nutritional qualities. The TTB in the notice states that a larger number
of consumer commentators were unaware that the information in the
proposed mandatory "Serving Facts" label is already displayed on many
alcohol beverage labels. This is indicative that not many consumers are
looking for this information when considering their alcohol purchases.

There seems to be a current trend among brewers and consumers of malt
beverages to be concerned about the caloric content of malt beverages.
This is evident in the recent introduction of a multitude of zero
calorie and light beers. The inclusion of a "Serving Facts" label should
be left up to the market to decide. If consumers are truly concerned
with the nutritional and caloric content of the beverages then it would
be in the best interest of the manufacturers to provide that
information. Additionally, roughly 30-40% of distilled spirits are sold
in bars and restaurants where a "Serving Facts" panel would not be
available to the consumer to consider prior to purchasing and consuming
the alcohol. The current TTB policy of voluntary disclosure of a
statement of average analysis on labels for all types and categories of
alcohol beverages should remain in place.

The requirement that breweries, distilleries, and wineries include the
percentage of alcohol by volume is a good amendment to the rule. Alcohol
content is something that is of interest to the consumer when deciding
what alcohol beverages to purchase and to consume. The fact that alcohol
content varies among wines, malt beverages, and distilled spirits makes
it difficult for the consumer to determine how much alcohol they have
consumed. I also agree with the TTB's assertion that the display of a
percentage of alcohol by volume is the best way to express alcohol
content on a product label or in advertisements. Consumers are familiar
with alcohol content expressed in this manner. By contrast, consumers
have little or no familiarity with alcohol expressed in U.S. fluid
ounces of pure alcohol.

Sincerely,

Christopher Leal