Wine Labeling
Alix Grabowski
May 2012

Wine comes in many colors, varieties, and vintages. It has long been a confusing product to the U.S. consumer, who is faced with hundreds of choices in the typical grocery store. However, wine is mysterious in another way besides the debate over which variety to buy. Its nutritional value is quite difficult to determine compared to other beverages.

In the U.S., the Food and Drug Administration (FDA) has strict labeling requirements for packaged food and beverage products. These requirements guarantee that consumers know what is in their food. The label discloses the food’s ingredients, how many calories and other nutrients it has, how much of it there is, as well as who made it and where (Bix 2012). However, there is one category of beverages that is not subject to many of these requirements: Alcohol.

Below are the labels of two products, one is a sparkling juice and the other is a wine. The labeling differences between the two quickly become apparent when the bottles are viewed side by side. A breakdown of the pieces of required information and which laws require them gives further insight.

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Both products require the declaration of the product name, the net weight of the contents, and the name and address of the manufacturer. All of the information is required by the Fair Packaging and Labeling Act of 1966, which was passed to provide consumers with the ability to make value comparisons between products (Bix 2012). The basic difference between the requirements for wine vs. the requirements for non-alcoholic beverages is that nutritional information is not required for wine. The Nutrition Labeling Education Act of 1990 required all food and beverage products under the auspice of the FDA, with a few exceptions, to list the ingredients of the food item in descending order by weight, nutrients in a nutrition facts panel, and comply with FDA standards for nutrition claims (Bix 2012). This act does not apply to wine or other alcoholic beverages. To understand why, one needs to investigate who regulates the labeling of wine, and why they have that responsibility.

While most packaged food and beverages are the responsibility of the FDA, wine and alcoholic beverage labeling is regulated by the Alcohol and Tobacco Tax and Trade Bureau (TTB). Excerpts from the mission statements of these two agencies are depicted below
.

fda


The reasons for the differences in the labeling requirements become clearer when the mission statements of the two agencies are considered. The FDA is charged with protecting the public health, which includes informing consumers of the contents of their food (FDA). The TTB’s focus is on protecting the consumer from being taken advantage of financially, and making sure the producers of alcoholic beverages are in compliance with the required permits and taxes. They are more concerned that a consumer is receiving a quality product at a fair price than if the consumer can evaluate the nutritional content of that product. The TTB uses more tools than just labeling to ensure alcoholic products are honest about their contents. Alcohol is one of only three categories of products in the U.S. to require tamper evident packaging (the other two are milk and over the counter drugs)(Bix 2012). The tamper evidence makes it more difficult for the alcohol to be watered down before sale.

But why the concern over fraud in alcohol sales when tamper evidence is not required for most other beverages? The short answer is simple: Prohibition.


timeline

The Federal Alcohol Administration Act, which authorizes the TTB to regulate the alcoholic beverage industry, was passed in 1935. This was just two years after the end of prohibition, and the concerns in the mission statement of the TTB naturally reflect the concerns of the time when it was created. The illegal production of all types of alcohol during prohibition resulted in poor quality and fraud being quite common in the industry. Wine quality in particular suffered because of a loophole in the prohibition laws allowed the home production of wine. This meant that people who had no idea how to make wine were the primary producers of it in the U.S. from 1918-1933 (Colman 2008). Quality naturally suffered during this period. This is the atmosphere under which the Federal Alcohol Administration Act was written, and as a result its main concern is ensuring the quality of alcoholic products, not educating the consumer on how many calories are in a glass of wine.

This raises the question, just how many calories are in a glass of wine? Is the lack of nutrition labeling on wine even a concern for consumers? The chart below breaks down the calorie content of wine versus other items.

calories

(Image Source: Freedigitalphotos.net)

As the graph demonstrates, a glass of white or red table wine has nearly as many calories as a can of soda, and a small glass of dessert wine actually has more (Nutrient Data Laboratory 2011). This is certainly enough calories to make a difference to consumers nutritionally; studies have shown that cutting just 150 calories per day can contribute to weight loss (Brownley 2007). Perhaps more surprising is the fact that 2 medium chocolate chip cookies have only about 60% of the calories as a 3.5oz serving of sweet dessert wine. If asked, how many people could correctly guess which of the above items had the most calories? During a trip to the supermarket, one could easily check the nutrition facts on the cookies, non-alcoholic wine, and the soda. The calories in the wines, however, would remain a mystery.

Most of the calories in wine are from the alcohol itself. The non-alcoholic wine has significantly fewer calories than its alcoholic counterparts (Nutrient Data Laboratory 2011). These are considered “empty” calories as they provide few nutrients. Furthermore, research has shown that when one drinks calories, they do not experience the same sensation of satisfaction or fullness that one gets from solid food. This is because the physiological signals the body uses to tell one’s brain that it has been fed are not usually triggered by liquid intake (Cederquist 2012). Since the amount of calories in a glass of wine varies with the alcohol content, it is particularly difficult to estimate the calories in a glass of table wine. Table wine is defined as wine with alcohol content between 7% and 14% by volume. These wines are not required to declare the exact percentage of alcohol they contain on their labels as long as it falls within this range (TTB 2008)
. All of this means that consumers are in the dark about wine’s nutritional information, and being uninformed could easily affect their health.

There is one required element on a wine label that one will not find on a non-alcoholic beverage package: The government warning. In 1988 an amendment to the Federal Alcohol Administration Act was passed that required all alcoholic beverages to include a government warning that explained the dangers of consuming alcohol (United States Congress, US Code Title 27 Section 215). The warning appears below as it does on alcoholic beverage packages:


“GOVERNMENT WARNING: (1) According to the Surgeon general, women should not drink alcoholic beverages during pregnancy because of the risk of birth defects. (2) Consumption of alcoholic beverages impairs your ability to drive a car or operate machinery, and may cause health problems.”

The warning was based on the findings of the Surgeon General, and it warns of the dangers of driving while intoxicated as well as the risks of consuming alcohol while pregnant. The warning is considered to be moderately successful in educating the public on the dangers of driving under the influence (MacKinnon 2008). The same law that made this warning mandatory also prohibited individual states from requiring any other warnings on alcohol (United States Congress, US Code Title 27 Section 215). It was thought that several different warnings would confuse the public and harm the industry. A single, uniform warning was therefore required in all states. Furthermore it was penned by a source authorized to contribute to public health policy: the Surgeon General. The Surgeon General is a member of the executive branch of government, under the department of Health and Human Services (which also houses the FDA). The mission of the office of the Surgeon General includes the duty to “Protect and advance the health of the Nation through educating the public” (Surgeon General).


The histories behind the laws and agencies that regulate the labeling of wine and other alcoholic beverages reveal the reasons for the differences between labeling requirements for these products and non-alcoholic beverages.
The major differences are the exclusion of nutrition and ingredient information from alcohol labeling, and the requirement of the government warning. The exclusion of nutrition information from wine and other alcohol labels keeps people in the dark about what they are consuming. Product labels are the main source of information consumers use to make decisions about the food and beverage products they consume. Labels, and what information is required on them, influence what people eat and drink.


References

"About FDA." What We Do. The United States Department of Health and Human Services. Web. 21 Apr. 2012. .

Bix, Laura. "Packaging Laws and Regulations." Packaging 480. Michigan State University, East Lansing. Spring 2012. Lecture.

Brownley, Erin. "Cutting Back 50 Calories with each Meal can significantly Contribute to Weight Loss." Sho - Ban News: 9. Ethnic NewsWatch. Mar 29 2007. Web. 18 May 2012 .

Cederquist, Caroline J. "Calorie in Alcohol - Liquid Calories Count, Even if they Dont Register." New York Beacon: 15. Ethnic NewsWatch. 2006. Web. 18 May 2012 .

Colman, Tyler. Wine Politics: How Governments, Environmentalists, Mobsters, and Critics Influence the Wines We Drink. Berkeley: University of California, 2008. Print.

"Department of Commerce." About the. United States Department of Commerce. Web. 21 Apr. 2012. .

MacKinnon, David P. "RIPL - Warnings." Arizona State University. Arizona State University, 1 Dec. 2008. Web. 21 Apr. 2012. .

"Surgeon General | SurgeonGeneral.gov." Surgeon General. The United States Department of Health and Human Services. Web. 21 Apr. 2012. .

United States Department of Agriculture. Agricultural Research Service. Nutrient Data Laboratory, 2011. USDA National Nutrient Database for Standard Reference, Release 24. Web. 25 Apr. 2012. .

United States Department of the Treasury. Alcohol and Tobacco Tax and Trade Bureau. ALCOHOL, TOBACCO PRODUCTS AND FIREARMS. Title 27 Code of Federal Regulations. LexisNexis Academic. Web. 21 Apr. 2012.

United States Department of the Treasury. Alcohol and Tobacco Tax and Trade Bureau. ALFD's Sample Wine Labels. Alcohol and Tobacco Tax and Trade Bureau, June 2008. Web. 21 Apr. 2012.

United States Congress. Federal Alcohol Administration Act. 1988. Title 27 Chapter 8 US Code. LexisNexis Academic. Web. 21 Apr. 2012.