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TTB Nutritional and Ingredient Labeling: Where Things Stand and What the Industry Thinks (WineAmerica)


Coming soon, WineAmerica expects three distinct TTB proposals that could drastically change beverage alcohol labeling requirements. 

By Michael Kaiser


Starting as early as this spring, WineAmerica expects TTB to announce three distinct regulatory proposals that could drastically change beverage alcohol labeling requirements. The first will be an Advanced Notice of Proposed Rulemaking (ANPRM) regarding ingredient labeling. The second will be a Notice of Proposed Rulemaking (NPRM) regarding nutritional information and serving facts disclosure. The third will be an NPRM regarding allergen disclosure.   

It’s difficult to form policy positions on hypothetical proposals, but soon enough these will no longer be hypothetical. To start forming a response that would represent the concerns of wine producers nationally, WineAmerica initiated an industry-wide survey to gauge interest and concern about these pending proposals. We did not ask about allergen disclosure in this survey.

Ingredient Labeling

The ANPRM on ingredient labeling is expected before summer. It’s an advanced notice because ingredient labeling was not included in the rulemaking proposals from 15 years ago. That’s important, as it will need to go through two rounds of public comments before TTB will issue a final ruling. TTB will seek public comments on the ANPRM and, based on the content of those comments, will decide to table the issue or proceed with an NPRM. That will start another round of public comments.

Perhaps the biggest question mark with ingredient labeling is, “What exactly is an ingredient in a bottle of wine?” Will it only include grapes, yeast, possibly sugar and sulfites? Or will it also include fining and/or filtering agents and anything else that might not be detectable in the finished product? 

The European Union has already instituted an ingredient labeling requirement on wine labels for any ingredient that “is not an allergen.” That would only include the basic ingredients in the finished product. Additionally, for ingredient and nutritional information, EU producers are allowed to disclose off-label by electronic means. That’s through the use of a QR code that takes consumers to a website that contains the information. 

The WA survey asked if ingredients should be disclosed on wine labels (or off-label) and 63% of respondents felt they should not have to disclose ingredient information. That’s a clear majority. However, the consensus from the specific comments is that the industry knows this is coming and, regardless of how they feel, producers know disclosure is probably inevitable. Half of respondents would be willing to accept an off-label solution.

Nutrition Labeling/Serving Facts

Turning attention to Nutrition Labeling and Serving Facts, there was an ANPRM on this topic issued many years ago and a temporary ruling issued, so the expected NPRM would be for the final rule. There have been many misconceptions about this. The truth is, wineries will have to disclose calorie, sugar and carbohydrate content, but every product will not need to be tested to discover this information. Voluntary disclosure is currently allowed, and the information can be calculated from the alcohol content of a 5-ounce serving of wine. 

If the TTB does rule to require nutrition content disclosure, it will be for all beverage alcohol products, not simply wine. Another question is when wineries will need to disclose this information. Will it be for prior vintages, or just for the wines bottled after a certain date?

A much higher percentage of survey respondents opposed nutrition labeling disclosure (80% of respondents were against the idea). However, the written comments again reflect the fact that most producers expect it to happen. The biggest takeaway from the survey is the need for an off-label solution for disclosure, which is what WineAmerica will advocate for as an option for all of these possible new requirements.

Timing and Implementation

Perhaps the biggest outstanding question regarding all of these proposals is timing. If the ANPRM for ingredient labeling is issued in the spring, as we expect it might be, there will be a three- to six-month comment period. Those comments will need to be reviewed by TTB, and then TTB will need to determine whether or not to issue an NPRM, which would also include a three- to six-month comment period. This would take us well into 2024 without a final rule issued.

Concurrently, we expect the two NPRMs on nutrition labeling and allergen disclosure to follow in the third and fourth quarters of this year. They will each have a three- to six-month comment period, and again, will go well into 2024. At the earliest, we won’t see any implementation dates on these proposals until early 2025. 

One thing is certain: WineAmerica will be spending a lot of time on this in the second half of 2023 and beyond. We have two Members Only webinars coming in the next two months. On May 24, we will be holding our second Listening Session on Nutritional Labeling, which will focus on consumer opinions. On June 8, WA will host a seminar on EU labeling requirements. These conferences are for WineAmerica members only. To join WineAmerica, please visit http://www.wineamerica.org/membership.


Michael Kaiser, WineAmerica
Michael Kaiser, WineAmerica

Michael Kaiser

Michael Kaiser is executive vice president and director of government affairs at WineAmerica, which represents wineries and associations from more than 40 states. For more information about WineAmerica and how to get involved, visit www.wineamerica.org.



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