Departments: Viewpoint from the April 2008 Magazine Issue
'Serving Facts' Serve Whom?
Considering false precision, calories and increased cost to wineries
by Bill Nelson
The Tax and Trade Bureau of the Treasury Department (TTB) is currently reviewing comments on a rulemaking proposal to mandate a "serving facts" information panel on all alcohol beverage labels, in type larger than two millimeters, set off in a box, and specifying alcohol content by volume, calorie and nutrient information (carbohydrate, fat and protein).
While at first glance it may seem reasonable to require wine labels to be similar to those for manufactured foods (see Editor's Letter, November 2007
), there are a couple of serious fallacies and problems inherent with that approach. The difference is that wine is not a "manufactured" product produced to constant specification, and nutrition labeling of wine can be misleading.
Wine is the product of fermentation of a variable fruit, influenced by location, climate, type of fruit and winemaking technique. It is not consistently produced to uniform specification, which is why TTB allows vintage labeling, why wineries have many small lots and different labels, and why there are so many prices and products in the marketplace. A wine's composition varies according to the grapes from which it is made, as well as the lot and year.
Thus each batch is potentially a different product. To get some grasp of the scope of this variation, note that in 2007, TTB approved 111,354 new wine labels.
Variability presents enormous challenges and potentially daunting costs to wineries, especially small wineries that might have to spend thousands of dollars to have nutritional testing done. Multiple label modifications will eliminate economies of scale in printing. The proposed serving facts panel will require significant space on the bottle, devouring precious real estate used by wineries to differentiate themselves from other wineries with similar products. Labels are important promotional tools for wineries. Customers often make their final purchase decision based on what they see and read on the wine label.
According to the TTB, the rulemaking is in response to a 2003 petition from the Center for Science in the Public Interest (CSPI), supported by a number of other organizations that believe such information "would directly assist consumers in measuring and moderating their drinking and evaluating the quality of the products." I question whether this approach, with all the costs and inherent damage to the more than 5,000 wine producers in this country, will, in any significant way, benefit consumers.
Does it really matter to consumers, and can they meaningfully process the difference between a wine with 98 calories per 5-oz. serving and one with 130 calories? Generally speaking, authorities recommend about 2,000 calories per day. Consumers certainly don't calculate with great precision whether they are consuming 2,200 or 2,400 calories.
Do they weigh each portion of meat they consume? Beef can easily contain between 150 and 900 calories, depending on fat content, trim and portion size. Even the scientific community has difficulty in determining the true metabolic value of alcohol calories, because there is great debate about the efficiency of converting ingested alcohol into usable metabolic energy. Some estimates are that alcohol calories are only 75% of their calculated value.
As recent studies on nutritional information are making increasingly clear, fresh foods are much preferable to manufactured foods, but come with an inherent difficulty in determining portion size as well as actual calories. These foods are not labeled for calories. Home kitchens are not laboratories where frenzied cooks carefully weigh each ingredient and calculate the resultant calories.
False precision is even more of a problem for fat, protein or carbohydrates. Wines don't contain any of these in significant quantity. Even CSPI sensibly suggests that their values should be ignored if a serving contains less than 5% of the "Daily Recommended Value." That essentially means ignoring fat and protein for ordinary wines, and also carbohydrates, since wines with residual sugar greater than 8% are typically consumed in smaller serving sizes.
Sensible public policy, the needs of consumers and the needs of America's wineries would be better served if TTB ruled against mandatory disclosure of calories and other nutritional information on wine labels. The various arms of the U.S. government could inform the public that a typical serving size for table wines is 5 oz., or 2.5 oz. for dessert or very sweet wines, and that such typical servings of wine contain approximately 120 or fewer calories. For wine consumers, following the dietary guidelines of two glasses or fewer per day, their maximum error would be on the order of less than 2% of their typical calorie intake. Such a simple message might actually break through to consumers who almost never actually look at the information panels on food packages.Bill Nelson is president of WineAmerica, the National Association of American Wineries. Wine-America's comments to the TTB regarding the proposed rulemaking are available on the WineAmerica website, wineamerica.org. To comment on this Viewpoint, e-mail firstname.lastname@example.org.
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