Statement of Linda Golodner

President, National Consumers League

October 12, 2005

Alcohol Facts Nutrition Label

Good morning, and thank you for coming. I am Linda Golodner, President of the National Consumers League based in Washington, DC.  Joining me is Barbara Moore, President of Shape Up America!  We will both make presentations and then be available for questions.

Every consumer should have access to labeling so they can choose and use consumable products -- from foods, beverages, dietary supplements, and medicines. The League was an advocate for a standardized “Nutrition Facts” panel on foods and non-alcoholic beverages.  We advocated for a similar “Drug Facts” panels on over-the-counter drugs and we support a “Rx Drug Facts” panel for prescription drugs. As a result, consumers now have access to labeling information about the ingredients and use of everything they eat, drink or swallow with one exception -- alcoholic beverages.

Today, the National Consumers League and Shape Up America! intend to change that.  Speaking on behalf of the public health, nutrition and consumer community, we are calling for immediate action to require a standardized “Alcohol Facts” panel on beer, wine and distilled spirits.  We call on the Alcohol and Tobacco Tax and Trade Bureau --  TTB -- to act now to implement an interim policy so that manufacturers of alcoholic beverages will be able to provide alcohol, calorie, ingredient and allergen information on their labels on a voluntary basis. This step will allow consumers to have limited access to this information while TTB works to implement a final rule, which may take several years.

Just recently, the Department of Health and Human Services and the U.S. Department of Agriculture issued the 2005 edition of Dietary Guidelines for Americans.  The Guidelines cite the adverse health consequences of excessive alcohol consumption and also note that moderate consumption of alcohol may convey health benefits.  The Guidelines say:

Those who choose to drink alcoholic beverages should do so sensibly and in moderation -- defined as consumption of up to one drink per day for women and up to two drinks per day for men.

As the scientific basis for this recommendation, the Dietary Guidelines cite evidence indicating that the “lowest all-cause mortality” and the “lowest coronary heart disease mortality” occur at an intake of one to two drinks a day, while heavy drinking increases the risk of many serious diseases and is the third leading cause of mortality in the United States.

With this much at stake, it is critical from a public health perspective that consumers have information to assist them in following the recommendation on moderate alcohol consumption as expressed in the Dietary Guidelines.  Alcohol Facts labeling is a way to provide this.

The consumer community hopes to reverse over 30 years of foot dragging by TTB and its predecessor agency, the Bureau of Alcohol, Tobacco and Firearms. In fact, efforts to require ingredient labeling on beer, wine and distilled spirits date back to 1972, when the Center for Science in the Public Interest first petitioned for this information. Based on CSPI’s petition, ATF issued a very weak rule in 1980 and then rescinded it in 1981. This led to a court challenge, after which ATF decided to reexamine its stance on ingredient labeling. However, in 1983, ATF again decided against labeling alcoholic beverages. At the time, ATF concluded and I quote: “there was no overwhelming desire on the part of consumers for comprehensive ingredient labeling.”

This record of ruling against consumers was challenged in 2003 when the National Consumers League joined with CSPI and 75 other public health and consumer organizations to petition TTB to require a standardized “Alcohol Facts” panel on all beverage alcohol products. Modeled after the label formats now required for virtually every other consumable product, our petition called on TTB to require labeling information about the alcohol, calories and ingredients that will help consumers make more informed choices about the consumption on alcohol.

This time, it took a year and a half for TTB to respond to our petition. On April 29, 2005, TTB issued an advance notice of proposed rulemaking calling for public comment on alcohol beverage labeling. In taking this step, TTB said: “It is now appropriate” to consider amending the regulations because and I quote “of increased interest in including nutrition and ingredient information on alcohol beverage labels.”

Now that the comment period has ended, the consumer community wants to go public with just how much interest exists for changing TTB policy. To make sure that TTB hears from the ordinary consumer, the National Consumers League commissioned Opinion Research Corporation to conduct a national random sample survey of 983 adult Americans aged 21 and over.  The results should end any doubt that the public wants the same access to standardized labeling information on beer, wine and distilled spirits that now appears on all other consumable products.

According to the findings, there is overwhelming support for major changes in TTB policy so that consumers will have access to standardized labeling information on beer, wine and distilled spirits.  Nine in ten Americans (89 percent) say that companies should be allowed to put information on their labels that will state how much alcohol is in a standard serving. Only 5 percent do not favor this action. Moreover, an equal number -- 86 percent -- believe that TTB should not prevent companies from disclosing this kind of information on labels.

Our survey also confirms that the public wants access to a wide variety of information about the contents of beer, wine and distilled spirits at the point of sale. Of special significance is having information about ingredients that may cause an allergic reaction. Here, 93 percent of those polled said that this information is needed while only 4 percent oppose this labeling.

At the same time, the public overwhelmingly favors TTB policy that would require mandatory ingredient and nutrition labeling. Of key importance to the public is including the list of ingredients, the number of calories per serving, the serving size, servings per container, alcohol per serving, carbohydrates per serving, fat per serving, and protein per serving.

Complementing these findings are the results of other opinion polls. For example, a survey conducted for the Center for Science in the Public Interest by the Global Strategies Group found that 77 percent of Americans strongly favor -- and 94 percent support alcohol content labeling for alcohol beverages.  Another telephone poll conducted by Westhill Partners and the National Journal’s Hotline in spring 2005 found strong support -- 83 percent in favor -- for voluntary labeling of alcohol content per serving.  

With both the public health community and consumers demanding change, the question for TTB is not whether but when. There is no reason to delay giving consumers access to the most basic information about alcoholic beverages.  We call on TTB to act immediately to amend its alcohol labeling and advertising regulations and guidelines.  

First, we call on TTB to implement an interim policy now so that manufacturers of alcoholic beverages can provide labeling information on a voluntary basis.  The Food and Drug Administration allowed voluntary nutrition labeling of foods before Congress mandated such labeling pursuant to the Nutrition Labeling and Education Act.

Second, we ask for quick action to finalize and implement new rules that will lead to a standardized “Alcohol Facts” panel on all beverage alcohol labels. At a minimum, this new labeling will provide the following basic information:

• The Serving size;

• The Amount of alcohol per serving;

• The Number of calories per serving; 

• The Percent alcohol by volume;

• The definition of a “standard drink”;

• The number of standard drinks per container;

• The advice on alcohol consumption in the current edition of the Dietary Guidelines for Americans; and

• An ingredients declaration listing each ingredient by its common or usual name and identifying any major food allergens present in the product.

The American public wants the same standardized labeling information on beer, wine and distilled spirits that now appears on all other consumable products, from foods and beverages to over-the-counter drugs.

Now, I would like to introduce Dr. Barbara Moore, President of Shape Up America! who will present the findings of the group’s review of the comments to TTB.