Pinot Law

TTB recently concluded the comment cycle of a rulemaking proceeding addressing nutritional label information for . . . wine. That’s right. The Federal Government wants to ensure that every wine consumer out there is informed of how many carbs, calories and other nutritional information is in each and every bottle of wine they purchase. Is this a good idea, or just the ‘Nanny State’ run amok.

From a policy perspective, this whole proceeding surprised me. Are consumers even interested in this information? Probably not. Are the ‘benefits’ associated with implementing these proposals enough to justify the substantial costs — particularly for small wineries? Doubtful.

TTB’s notice of proposed rulemaking (NPRM), sought to answer some of these questions. I found their answers lacking.

For example, on the consumer interest front, TTB claims “numerically significant” public support for its proposal based on the fact that about 18,000 consumers signed an online petition supporting such disclosure. But when you consider that some estimates put U.S. wine drinkers at 64 million consumers, that 18,000 is hardly “significant”. It’s downright tiny.

TTB acknowledged that much of that support was generated through the “Know Your Drink” website. That website — which extols the virtues of mandatory wine labeling — was sponsored by Diageo, which also happens to be a $3 billion dollar a year, multinational corporation with more than 22,000 employees in excess of 80 countries. Gee. Why would a multi-billion dollar, multinational corporation want to impose onerous regulatory obligations that will increase costs for wine and alcohol manufacturers, particularly smaller competitors who happen to be creeping into the market share of larger brand name companies? I wonder.

Anyway, I will be writing some more about this issue in the weeks ahead, but in the meantime, you can read comments I filed at the TTB on behalf of my vineyard here (my comments are on the last page).

Nutrition Info used under a Creative Commons License provided by blmurch.