Comment from Westwood Winery (Kelly, John M.)

Document ID: TTB-2007-0062-0004
Document Type: Public Submission
Agency: Alcohol And Tobacco Tax And Trade Bureau
Received Date: August 01 2007, at 03:14 PM Eastern Daylight Time
Date Posted: September 12 2007, at 12:00 AM Eastern Standard Time
Comment Start Date: July 31 2007, at 12:00 AM Eastern Standard Time
Comment Due Date: January 28 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 80270ca5
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This is comment on Proposed Rule

Notice No. 73 -- Labeling and Advertising of Wines, Distilled Spirits and Malt Beverages

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RE: Docket ID TTB-2007-0062 Labeling and Advertising of Wines, Distilled Spirits and Malt Beverages (Serving Facts Labeling) I have two major objections to the proposed rulemaking: 1) In proposing to require producers of alcoholic beverages to state the caloric, carbohydrate, fat and protein content per serving of their products, TTB is improperly arrogating to itself regulatory authority that is vested in the Food and Drug Administration. It should be up to Congress to determine if alcoholic beverages will be regulated by TTB, FDA, or both. 2) Congress should not determine that alcoholic beverages are "food" and therefore subject to food content labeling requirements (nor should TTB), as such a labeling requirement is inherently disadvantageous to small producers. Food content labeling requirements will give an anti-competitive advantage to large producers of alcoholic beverages. Respectfully, s/ John M. Kelly