Comment from Rath, Alan R.

As a wine enthusiast, I would like to comment on the proposed rule change to require a Serving Facts Panel on alcoholic beverages, in particular wine. I strongly believe this is unnecessary, and an overreach of the what ATTTB should be regulating. Here are my reasons: 1) Most wine contains little or no nutritional value in the way of carbohydrates, protein, sugars, etc. The alcohol content currently reported on all labels is really the only dietary information of any value to a consumer. 2) Though some wines are produced in huge quantities, where a Serving Facts requirement would be of little consequence to the cost of production, the majority of wine labels are from small producers, and low production wines - often in the hundreds of cases or less. Requiring this information will put an undue burden on these producers in terms of the costs of analysis of each wine (as many as a dozen or more different small bottlings), as well as the approval and production of the label itself. 3) Foreign producers may simply decide not to export their wines to the US because of the costs and difficulties of meeting more complex regulatory requirements. This would reduce the choice I have as a consumer in buying wines from around the world. In short, while it might make sense for a large producer of beer or other beverages (where there are significant carbohydrates and calories in a bottle, and where large numbers of bottles are produced, always the same from batch to batch) to voluntarily include such information, it makes no sense for producers of wine, and places an undue burden on the smaller producers. I believe this would hurt me as a consumer, by raising prices and limiting choices, more than help me by providing information that has no real value. The regulations on the wine industry are already complex, and costly for producers to follow - passed on to me as a consumer. Please don't add additional layers of complexity and cost, with no benefit to the consumer. Sincerely, Alan Rath