^Major Food Allergen Labeling for Wines, Distilled Spirits, and Malt Beverages – A Proposed Rule by the Alcohol and Tobacco Tax and Trade Bureau^
AVFCA Commentary: On behalf of A Voice for Choice Advocacy, we believe that the Alcohol and Tobacco Tax and Trade Bureau (TTB) should mandate ingredient labeling of all contents used in the production of alcoholic beverages regulated under the Federal Alcohol Administration Act. This requirement is essential for several reasons.
Firstly, food allergies are a significant public health concern. According to the Centers for Disease Control and Prevention (CDC), approximately 32 million Americans suffer from food allergies. Currently, many consumers remain unaware that alcohol beverages often lack proper ingredient labeling, including allergen labeling requirements established by the Food Allergen Labeling and Consumer Protection Act (FALCPA). By requiring comprehensive ingredient disclosure, TTB would empower consumers to make safer choices, mitigating the risk of unforeseen reactions, including triggering allergic responses.
Secondly, transparency in labeling aligns with modern consumer expectations and public health advocacy. In 2021, various consumer groups and public health advocates called for mandatory labeling, emphasizing that consumers should have full access to information about the content of the products they consume. The public has expressed dissatisfaction with the current voluntary labeling system, which upholds ambiguity. A standardized disclosure of all ingredients would be a significant step toward greater transparency and consumer protection.
Furthermore, the TTB possesses the statutory authority under the Federal Alcohol Administration Act to ensure that consumers receive "adequate information" about the identity and quality of alcohol products. The absence of mandatory ingredient labeling represents a gap in consumer protection that the TTB is well-positioned to address. Implementing such regulations would not only enhance consumer awareness but also foster trust in alcohol brands that prioritize transparency and safety.
Lastly, the proposed regulations align with the TTB's mission to protect public health and well-being. By establishing uniform ingredient labeling requirements, the TTB would not only fulfill expectations set forth in previous public health initiatives but also adhere to the discussions and recommendations highlighted in the Treasury’s Competition Report on alcohol markets. This report emphasizes that regulatory actions promoting public health should take precedence. Establishing a consistent framework for full ingredient disclosure would reflect a proactive response to these recommendations.
In conclusion, mandating ingredient labeling on alcohol beverages is a vital initiative that would enhance consumer safety, ensure compliance with public health standards, and fulfill the TTB's regulatory responsibilities. Such requirements would provide Americans - particularly those vulnerable to food allergies, and/or sensitive to a diverse range of ingredients - with the necessary information to make informed choices about their consumption of alcohol beverages.
https://www.regulations.gov/comment/TTB-2025-0003-0040
Firstly, food allergies are a significant public health concern. According to the Centers for Disease Control and Prevention (CDC), approximately 32 million Americans suffer from food allergies. Currently, many consumers remain unaware that alcohol beverages often lack proper ingredient labeling, including allergen labeling requirements established by the Food Allergen Labeling and Consumer Protection Act (FALCPA). By requiring comprehensive ingredient disclosure, TTB would empower consumers to make safer choices, mitigating the risk of unforeseen reactions, including triggering allergic responses.
Secondly, transparency in labeling aligns with modern consumer expectations and public health advocacy. In 2021, various consumer groups and public health advocates called for mandatory labeling, emphasizing that consumers should have full access to information about the content of the products they consume. The public has expressed dissatisfaction with the current voluntary labeling system, which upholds ambiguity. A standardized disclosure of all ingredients would be a significant step toward greater transparency and consumer protection.
Furthermore, the TTB possesses the statutory authority under the Federal Alcohol Administration Act to ensure that consumers receive "adequate information" about the identity and quality of alcohol products. The absence of mandatory ingredient labeling represents a gap in consumer protection that the TTB is well-positioned to address. Implementing such regulations would not only enhance consumer awareness but also foster trust in alcohol brands that prioritize transparency and safety.
Lastly, the proposed regulations align with the TTB's mission to protect public health and well-being. By establishing uniform ingredient labeling requirements, the TTB would not only fulfill expectations set forth in previous public health initiatives but also adhere to the discussions and recommendations highlighted in the Treasury’s Competition Report on alcohol markets. This report emphasizes that regulatory actions promoting public health should take precedence. Establishing a consistent framework for full ingredient disclosure would reflect a proactive response to these recommendations.
In conclusion, mandating ingredient labeling on alcohol beverages is a vital initiative that would enhance consumer safety, ensure compliance with public health standards, and fulfill the TTB's regulatory responsibilities. Such requirements would provide Americans - particularly those vulnerable to food allergies, and/or sensitive to a diverse range of ingredients - with the necessary information to make informed choices about their consumption of alcohol beverages.
https://www.regulations.gov/comment/TTB-2025-0003-0040
Legislation Details
Bill Name: Major Food Allergen Labeling for Wines, Distilled Spirits, and Malt Beverages
Bill Number: Docket No. TTB-2025-0003; Notice No. 238
Bill Author(s): Department of the Treasury Alcohol and Tobacco Tax and Trade Bureau
Legislative Session / Year: 2025
State: Federal
AVFCA Position: Support
Bill Synopsis: The Alcohol and Tobacco Tax and Trade Bureau (TTB) proposes to require a labeling disclosure of all major food allergens used in the production of alcohol beverages subject to TTB's regulatory authority under the Federal Alcohol Administration Act. Under the proposed regulations, unless an exception applies, labels must declare milk, eggs, fish, Crustacean shellfish, tree nuts, wheat, peanuts, soybeans, and sesame, as well as ingredients that contain protein derived from these foods, if used in the production of the alcohol beverage. TTB proposes a compliance date of 5 years from the date that a final rule resulting from this proposal is published in the Federal Register.
LegInfo Bill Link: https://www.federalregister.gov/documents/2025/01/17/2025-00955/major-food-allergen-labeling-for-wines-distilled-spirits-and-malt-beverages
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