Comment 04116484

From: Nicole Raak [nr@wafed.com]
Sent: Monday, September 26, 2005 11:55 AM
To: Rulemaking, TTB
Subject: Comments - Notice No. 41, Labeling and Advertising of Wines, Distilled Spirits, and Malt Beverages



 









Society for Nutrition Education
7150 Winton Drive, Suite 300
Indianapolis, IN 46268

www.sne.org





Chief, Regulations and Procedures Division

Alcohol and Tobacco Tax and Trade Bureau

Attn: Notice No. 41 & 48

P.O. Box 14412

Washington, DC 20044-4412



Re:       Notice No. 41





Dear Sir or Madam:



The Society for Nutrition Education (SNE) respectfully submits comments to the request set forth by the Alcohol and Tobacco Tax and Trade Bureau (TTB) on the above Notice on Labeling and Advertising of Wines, Distilled Spirits, and Malt Beverages. 



SNE is an international organization of nutrition education professionals who are dedicated to promoting healthy and sustainable food choices and who share a vision of healthy people in healthy communities.  Our members conduct research in education, behaviors, and communication; develop and disseminate innovative nutrition education strategies; and communicate information on food, nutrition and health issues to students, professionals, policy makers and the public.



SNE urges TTB to require mandatory nutrient and allergen labeling on all alcoholic beverages - beer, wine and distilled spirits products. 



Intake of excess calories is a problem for a large number of adults, and information about where those calories are hidden will be important for individuals who consume alcohol without realizing the number of calories it contains.  Standardized label information about the alcohol and calorie content of alcoholic beverages will be an important tool for adults to make more informed decisions about how much, if any, alcohol they should consume. As educators we value tools that improve knowledge transfer, allowing consumers to make mindful food and beverage choices to promote overall health.



SNE recommends that at a minimum the "Alcohol Facts" panel information contain, in a standardized format: 

        The serving size (i.e., 12 fluid ounces (fl oz) for beer, 5 fl oz for wine, and 1.5 fl oz for distilled spirits);

        The amount of alcohol (in fluid ounces per serving);

        The percentage alcohol by volume;

        The number of calories per serving;

        The definition of a "standard drink"; and

        The number of standard drinks per container

        The admonition to drink moderately with reference to the Dietary Guidelines for Americans 2005.

        Grams of  alcohol, carbohydrates, fats and proteins 

        The number of calories per 1 gram of alcohol, carbohydrates, fat and protein (7, 4, 9,4 respectively)



We also urge that the label contain information from the Dietary Guidelines for Americans 2005, that suggests a limit of two standard drinks per day for men and one for women. Our members feel fundamental messages about drinking in moderation are important to general population public health and safety. Therefore, SNE recommends that TTB require moderate drinking messages in all alcoholic beverage advertising and labeling and other safety messages that have been and are identified (e.g. drinking during pregnancy).



Further, because alcohol beverages may contain major food allergens, such as sulfites and glutens, it would also be helpful if TBB requires the labels of all alcoholic beverages to identify any major food allergens present in the product. The public has a right to know the ingredients used to make any product that is to be ingested. Identification of major food allergens is necessary to ensure that consumers with food allergies have the information they need to avoid those allergens.   



SNE does not feel that priority should be given to harmonizing TTB requirements with other major alcohol producing nations. Further we encourage TTB to require all nations that import alcoholic beverages to comply with the requirements set forth in the U.S.



Rule making often takes a long time, so SNE suggests that TTB issue an interim policy allowing bottlers to provide a definition of standard drink, a definition of moderate drinking, alcohol content, calorie and allergen information on their labels on a voluntary basis. Having this information, even on a voluntary basis, will help make the public aware of the alcohol and caloric content of the alcohol beverage products they consume.  Not only is this a consumer right, but the health of the public would be better served if Americans had ready access to information about the alcohol content, calories, and serving sizes of the beer, wine and distilled spirits they are consuming.



Thank you for the opportunity to provide comments.  Any questions or response can be referred to Mary Ann Passi, Executive Director, Society for Nutrition Education at 1-800-235-6690.

Sincerely,



Patricia Kendall, PhD, RD

President 

Society for Nutrition Education