Remarks: Barbara J. Moore, PhD
President, Shape Up America!
October 12, 2005

Alcohol Facts Nutrition Label

Shape Up America! is a non-profit organization founded in 1994 whose mission is to encourage a better diet and lifestyle in all individuals and healthy weight loss in overweight individuals that can be sustained over time. We have been a strong and consistent voice calling for complete information to guide consumer choices – and that includes information about the alcohol and calorie content of beer, wine and distilled spirits.  We have worked hard to provide responsible information to the public health community to increase understanding and garner support for a standardized “Alcohol Facts” panel providing labeling information about these beverages. For the sake of weight management, this information is long overdue.

Today, the vast majority of foods, beverages, over-the-counter drugs and dietary supplements carry standardized labeling information to tell consumers what is in the products they purchase for themselves and their families. The same information needs to appear on the labels of absolutely all beverage alcohol products. Not only is this a consumer right, but in our view, it is a critical public health need. Americans need ready access to information about the alcohol content, calories, and serving sizes of the beer, wine and distilled spirits they are consuming.

Here are some of the strong public health policy arguments for requiring “Alcohol Facts” and ingredient information.
 

First, because obesity is a calorie balance issue, having information about the calories in alcoholic beverages is one important step in our overall strategy to address overweight and obesity. The Dietary Guidelines for Americans 2005, states that more than 55 percent of American adults consume alcohol-containing beverages and defines moderate drinking as no more than one drink per day for women and two drinks a day for men.  Because alcohol is disinhibiting, the consumption of alcohol-containing products can result in the intake of a significant number of calories, and needs to be carefully monitored.  But without calorie information on these products, the typical consumer who is interested in weight management cannot do this calorie monitoring.

In response to the national obesity epidemic, the 2004 FDA report, Calories Count, reminds us that we need to balance the calories consumed in food against the calories expended in physical activity. In other words, it makes no sense that most alcohol beverage labels contain no information about calories. Clearly, making this information available is a health priority.

Another important health issue is food allergies.  Thorough labeling will help consumers with food allergies avoid specific allergens that might be present in beer, wine and distilled spirits. TTB should require beverage alcohol manufacturers to list the ingredients in their products in layman’s language and to identify any major food allergens present in the product.

Although scientific research has documented certain health benefits of moderate alcohol consumption, there are serious health risks associated with excessive consumption of alcohol. Increased risk of liver cirrhosis is associated with chronic over- consumption of alcohol. And there is the risk of serious injury or even death caused by driving or operating machinery while intoxicated. There is also convincing evidence that alcohol consumed in excessive amounts is linked to cancer of the mouth, pharynx, larynx, oesophagus and liver.  The evidence for a link to colon, rectum and breast cancer is rated "probable," and the link to lung cancer, is rated "possible."  Among the 55 percent of adult Americans who drink, there is considerable confusion about what constitutes “moderate” drinking.  The “Alcohol Facts” panel could and should address this problem by clearly defining what it means.

When the Dietary Guidelines define moderate drinking as no more than two standard drinks per day for men and one standard drink per day for women, the challenge is to clearly define what is meant by a a “standard drink.”  The proposed labeling of alcoholic beverages that we support would accomplish this and would thereby help adults to estimate and monitor their alcohol consumption.

For all of these reasons, there is no debate within the public health and nutrition community about the need to mandate an “Alcohol Facts” label panel and ingredients declaration on all beverage alcohol products. But until now, there has been no gauge of the extent to which leading academic institutions and professional societies support these changes to public policy.  We now know that the public health community is unanimously calling for complete labeling information on beer, wine and distilled spirits products.

Shape Up America! conducted a top-line review of the letters posted to the TTB Web site as of October 5, 2005. Of the 18,626 letters TTB posted, 17,876 were in support of additional labeling for alcoholic beverages. Put in simple terms, an overwhelming 96 percent of all the comments TTB received were in support of labeling. There were only 750 letters in opposition, or approximately 4 percent of all the letters received.

Besides these impressive numbers, Shape Up America’s review also identified the sources of this support. In addition to many national consumer organizations and members of the public, those taking a stand included the staff of the Bureau of Consumer Protection, the Bureau of Economics and the Office of Policy Planning at the Federal Trade Commission. Further, we counted a number of national public health organizations, such as the American Medical Association, American Dietetic Association, American Society of Addiction Medicine and the American Public Health Association and we know more such organizations have submitted comments. Moreover, respected faculty from a number of leading medical schools, including Harvard and Yale, have weighed in along with some prominent public health officials, such as former Surgeon General C. Everett Koop.

While these comments vary in emphasis, our review finds common ground among these stakeholders regarding what information must be included on beverage alcohol labels. Specifically, we found overwhelming support for giving consumers access to the following information:

1)      The serving size -- In other words, 12 fluid ounces for beer, 5 fluid ounces for wine, and 1.5 fluid ounces for distilled spirits;

2)      The number of calories per serving;

3)      The amount of alcohol per serving; and

4)      The Dietary Guidelines’ advice on moderate drinking -- That is no more than two drinks per day for men and one drink per day for women.

Although not all groups commented about the need for ingredient labeling, there was overwhelming support among those that did -- calling for the identification of any major food allergens present in the product. Not every group commented about including information about the fat, carbohydrate, and protein content of beverage alcohol products. However, among those who did, we found a consensus that because alcohol provides few essential nutrients, this information should be optional unless the product makes a carbohydrate claim. Then, carbohydrate information should be required.

Taken together, Shape Up America’s review of the more than 18,000 public comments received by TTB suggests that there is no debate over the need for the agency to undertake a comprehensive reconsideration of labeling requirements for alcohol beverages. Current labeling requirements for alcoholic beverages are outdated. They do not reflect current scientific knowledge about health and safety matters and they do not demonstrate the national leadership that is critically needed to address the growing epidemic of obesity. 

In our view, maintaining the status quo is unacceptable. As a matter of public health, there is no reason for TTB to delay implementing new rules that will lead to a standardized “Alcohol Facts” panel on all beverage alcohol labels. Speaking on behalf of the 17,876 organizations and individuals writing in support of more disclosure of consumer-friendly information on alcohol labeling, the time for action is now.  Thank you.