Comment from Seavey Vineyard (Reid, Matthew S.)

I am the winemaker at a ~3,000 case winery and 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 beyond the regulatory scope of the TTB. 1) The vast majority of wine contains little or no carbohydrates, and I do not believe that any wines contain protein or fat. Alcohol content is already stated on the label. 2) The costs of analyzing the "nutritional" content of each wine would be extremely burdensome to small producers, especially those who produce a number of bottlings and cannot afford to perform such analysis in-house. This would likely have the effect of discouraging innovation and creativity at smaller producers and would diminish consumer choice as wineries choose to produce fewer products. Costs associated with this rule might even force some wineries out of business as their small margins are squeezed even further. 3) The costs associated with complying with this rule could further diminish consumer choice by discouraging foreign producers from exporting wine to the United States due to the complex regulatory requirements. As a wine consumer I would find this distressing and disappointing, but even from my perspective as a wine producer this proposed rule would be unacceptable, unwarranted, and unneeded protectionism. I believe this proposed rule should not be made final. If it is made final I believe that wines, or at the very least, dry table wines, should be exempt. If wines are not exempt from the labeling requirements then I believe a modified label, without the lines for PROTEIN and FAT, should be allowed for wines. I reiterate that this is essentially a protectionist rule that would hurt consumer choice by reducing the number of domestic and imported wines available and by raising prices. Sincerely, Matthew Reid Seavey Vineyard