I think that this proposal will not work for WINE. There are a few reasons it would
turn things upside down, and I am very worried. I work for a wine importer, in the
operations dept. If we were to be forced to add these labels to wine bottles, then
the negetive effects would far outweigh any positive effects for the customer. To
begin with, having to display the alcohol content would be fine, and is already part
of the everyday practice in wine labeling. The serving size should be decided by
the consumer. They are educated in school and it is general knowledge that one
glass of wine = one beer = one shot. Wine glasses are all different sizes, and no
consumer EVER measures the wine they pour. Therefore, there would be no way,
save distributing measurement devices with these bottles, that a consumer would
be able to accurately measure a single serving, no matter what that quantity is
listed as on the bottle. Furthermore, and more importantly, the last thing the
growing wine industry needs is for winemakers and distributors to have to regulate
the calories per serving. Each barrell of wine will register with a different caloric
density, as would each bottle. It would be very difficult to measure the calories per
serving accurately. Also, imagine an industry like beer, where wineries feel the
need to offer a wine with the "least calories per serving." This would strongly
compromise the idea of quality wine-making and competition based on
quality. "Chardonnay lite" is not a product that needs to be introduced to the
american public. It will taste horrible, and destroy the consitant quality many
wineries are known for. In closing, I would like to say that wine drinkers know what
to expect in a serving of wine, and how much they should drink. They generally do
not consume wine solely for intoxicating purposes, as many hard liquor and some
beer drinkers do. The industry will be negetively affected by this proposal, and I
speak out strongly against it. If we're talking compromise, standardize the
inclusion of alcohol %, as consumers should always know how strong the wine is,
and it is already considered "the norm" to list this on the bottle. Thank you for you
time and consideration.
-Adam Klagsbrun.
Comment from Klagsbrun, Adam J.
This is comment on Proposed Rule
Notice No. 73 -- Labeling and Advertising of Wines, Distilled Spirits and Malt Beverages
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