Comment 2: Augenstein, Daniella

Following review of the rule and the proposed changes to it, I support the proposal to add “country” to the list of accepted appellations of origin for the labeling of vintage wines, and suggest that the proposal be allowed to pass to implementation. My various perspectives toward this market (as a consumer, one who has studied this product for the purposes of personal edification, and a studying economist) render me at the very least minimally qualified to make an educated statement as to the potential benefits or losses that may result from this proposal. I am, as a general rule, in favor of giving business owners and operators the room that they need to decide the best decisions to make within their companies, without external interference. By changing the regulations to allow for a vintage date to appear on a wine that is labeled with a country as an appellation of origin, the TTB will enhance flexibility of wine producers to label their product, as well as expand their options for sourcing the grapes used in the production of their wines. As the proposal states in the Summary section, and because nothing else is altered in the regulation, consumers may still be assured that they are being provided with “adequate information as to the identity and quality of the wines they purchase.” One would wonder why a country was ever deemed an inappropriate designation for an appellation of origin in the first place. Boundaries and borders are determined by political officials, among others (as are the viticultural areas in the United States). With this proposal, an absurd regulation will cease to exist, and will allow countries to join the ranks of other types of regions as an accepted appellation of origin for the labeling of vintage wines.