Comment from Klagsbrun, Adam J.

Document ID: TTB-2007-0062-0007
Document Type: Public Submission
Agency: Alcohol And Tobacco Tax And Trade Bureau
Received Date: August 02 2007, at 12:51 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: 80271564
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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.

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