NCHR Comment on Labeling and Advertising of Beverages with Alcohol Content

Labeling and Advertising of Wine, Distilled Spirits, and Malt Beverages with Alcohol Content, Nutritional Information, Major Food Allergens, and Ingredients

Docket No. TTB-2024-0002

We appreciate the opportunity to provide our views to the Alcohol and Tobacco Tax and Trade Bureau (TTB) regarding the urgent need for TTB to initiate rulemaking to improve the labeling of wine, distilled spirits, and malt beverages to include per-serving alcohol and nutritional information, major food allergens, and/or ingredients.

The National Center for Health Research (NCHR) is a nonprofit think tank that conducts, analyzes, and scrutinizes research on a range of health issues, with a particular focus on which prevention strategies, treatments, and products are safe and/or effective for patients and consumers. We do not accept funding from companies that make products that are the subject of our work, so we have no conflicts of interest. 

Research indicates that alcohol consumption can increase the risks of several types of cancer as well as premature death. Alcohol has been directly linked to 5.6% of all cancer cases that are diagnosed each year, including cancers of the oral cavity, pharynx, larynx, liver, esophagus (squamous cell carcinoma), female breast, and colorectal cancer.¹ Therefore, requiring useful information on the label will save lives.  

Consumers benefit from information about the products that they use and especially those they consume. It is therefore imperative to provide useful, understandable information on labels for wine, distilled spirits, and malt beverages. In addition to alcohol, alcoholic beverages often contain added sugars, calories, and allergens. Consumers should have easy access to this information to ensure their safety and to make informed decisions that have life-saving implications for their health.

Requiring clear, understandable information regarding calories, ingredients, nutritional information, and serving size on the packaging of alcoholic beverages will:

• Enable consumers to avoid allergens and excess sugar intake, make decisions about caloric intake, and manage or prevent diet-related conditions.
• Provide information on the total amount of alcohol in the container (not just alcohol by volume) so that consumers can make informed choices and avoid excessive consumption.

Improvements to the labeling requirements of alcoholic beverages are long overdue. Currently, most TTB-regulated alcoholic beverages lack ingredient disclosures or Serving Facts. According to a Center for Science in the Public Interest study of labels from top brands in 2021, there is extremely low compliance with TTB’s voluntary labeling guidelines.² It is clear that voluntary standards are not sufficient, because industry has no incentives to provide information that might result in lower sales.  We urge the TTB to enforce mandatory disclosure of nutritional information, serving size, and ingredients in alcoholic beverages. Technological barriers to the information, such as QR codes instead of explicit information on the bottle or can, are not sufficient. Consumers would greatly benefit from mandatory labeling that includes nutrition facts, ingredients, allergens, alcohol content, and serving size, plus servings and standard drinks per container.  Such a rule would represent an important, life-saving step to ensure consumer health and safety and foster accountability of the alcoholic beverage industry.

 [1] Klein WMP, Jacobsen PB, Helzlsouer KJ. Alcohol and Cancer Risk: Clinical and Research Implications. JAMA. 2020;323(1):23–24. doi:10.1001/jama.2019.19133

[2] ASN alcohol labeling poster.jpg (5376×4032). (n.d.). Retrieved March 29, 2024, from https://www.cspinet.org/sites/default/files/2024-02/ASN%20alcohol%20labeling%20poster.jpg

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