Alcohol Labeling: Industry Interests Trump Consumer Needs George A. Hacker NABCA Annual Administrator’s Conference October 27, 2008

CSPI/NCL Label Proposal (December 2003)

Key Elements of Original Proposal Alcohol-focused information and emphasis on calorie content Disclosure of ingredients Graphic illustration to highlight number of servings per container Dietary Guidelines definition of “moderate drinking” Dual expression of alcohol content

TTB Proposed Label: 375 mL Bottle of 14% ABV Wine

TTB Proposed ‘Optional’ Label: 750 mL Bottle of 14% ABV Wine

TTB Response Carbs, Fat, Protein (“Serving Facts” instead of “Alcohol Facts”) No ingredients No definition of moderate drinking Voluntary disclosure of alcohol content on informational panel Voluntary disclosure of alcohol content in fluid ounces (together with ABV)

What’s Wrong with TTB Proposal? Fails to require alcohol-content disclosure in Serving Facts Panel; would permit 3 versions of those information panels. Requires disclosure of extraneous, irrelevant protein and fat content. Ignores contextual advice on moderate drinking. Not supported by adequate consumer research.

Labeling Principles (American Dietetic Association) Label claims should be clear and understandable to consumers. The label must be truthful and not misleading. Content on the label should help consumers make informed decisions to build a healthy diet. Label content should have consistent type and format so products can be read and consumers can make product comparisons. All claims should include labeling of accurate quantitative information about the dietary substance, including percent of Daily Values in a single serving of the product, when known, or the daily dietary intake necessary to achieve the claimed effect. Consumer research is imperative before making changes to the label. Source: American Dietetic Association Labeling Task Force, January 17, 2006

ADA believes that consumer research is critical in determining whether labeling formats and contents are understandable and for ensuring that allowable nutrient and health claims are not misleading. Furthermore, consumers should be able to understand the information in the context of their total diet and their individual health concerns. Source: American Dietetic Association Labeling Task Force, January 17, 2006

Some Research Questions (based on nutrition labeling) Consumer Comprehension –Comparing products –Judging healthfulness –Verifying claims –Estimating servings to meet daily requirements –Balancing nutrients

Some Research Questions (based on nutrition labeling) Acceptance of Displayed Information –Graphics –Metric units –Percentages –Interpretational Aids –Gender/age differences Are effective label formats necessarily those most preferred by consumers?

CSPI Comments: (Beer label proposed for consumer research)

Voluntary UK Label

Industry Issues Promotion of “Equalization” for spirits Marketing alcohol as a diet drink Passing alcoholic beverages off as food Shrinking the public perception of alcohol content

Distillers’ Message to TTB from Congress (6 members) Support “nutrition” information for consumers; inform decisions about their “diets and lifestyle.” Include definition of “standard drink” and amount of alcohol per serving. Give consumers information to make “responsible drinking decisions and more easily follow the recommendations of the U.S. Dietary Guidelines on alcohol consumption.” (but no mention of including them on the label) Correct TTB’s creation of arbitrary serving sizes for beer, wine, and spirits.

Rolling Stone, Jan 26, 2006

Brewers’ Message to TTB from Congress (>70 members) Statutory requirements differ among beverages (subtext: beer is subject to less regulation, because it’s less potent). Labeling should reflect the significant differences in alcohol content of beer, wine, and liquor. Say “No” to graphic depictions of a “standard drink.” Say “No” to alcohol information expressed in fluid ounces (too confusing for consumers).

Maxim, November 2007

Maxim, May 2003

Cosmopolitan, July 2005

Consumers’ Letter from Congress (Sens. Lautenberg and Murkowski) More research on content and placement of informational panel. Alcohol content should be required to appear on a uniform informational panel. Fat and protein content to be listed only if those nutrients meet threshold amounts.

Consumer Federation of America, June 30, 2008

Shape Up America! Alcohol Labeling Poll: Major Findings When informed about the specific advice regarding moderate drinking, nearly 4 in 5 Americans (79%) say it would be useful to know the Guidelines defines “moderate consumption” of alcoholic beverages as up to two drinks per day for men and up to one drink per day for women. When informed that TTB is considering requiring mandatory labeling on all beer, wine and distilled spirits products, nine in ten (90%) support this action and the level of support transcends demographics, political affiliation and alcohol usage. Of those surveyed, 44% agreed strongly that mandatory labeling is needed. Only 4% strongly oppose government action. When read a list of types of information that could be included on an alcoholic beverage label, consumers ranked “the amount of alcohol in each drink” first (92%) followed by calories (84%) and information about what the Dietary Guidelines recommend (77%).

Convenience and Novelty Packaging

Pocket Shot Single Serve Pouches

Spykes

Go Wodka Booze Tubes

Bong Vodka

Wineside Test Tube Wine Tasters

JustMiniatures Test Tube Shots

Vertikal Vodka

Nuvo Sparkling Vodka Liqueur

267 Vodka Infusions

Booz2Go

Georgia Moon Corn Whiskey

Baroques’ Wine in a Can

For more information: George A. Hacker Director, Alcohol Policies Project Center for Science in the Public Interest Washington, DC