ACSA Submits Comments to TTB on Proposed Rules for Alcohol Facts Statements and Major Food Allergen Labeling

Last week, the American Craft Spirits Association (ACSA) submitted comments to the U.S. Alcohol and Tobacco Tax and Trade Bureau (TTB) in response to proposed rules on alcohol facts labeling and major food allergen labeling for wines, distilled spirits, and malt beverages.

In response to Alcohol Facts Statement in the Labeling of Wine, Distilled Spirits, and Malt Beverages (Notice No. 237), ACSA urged TTB to exempt small distilleries from the proposed Alcohol Facts labeling requirements, noting that the added costs would disproportionately impact small producers while offering little public benefit. ACSA emphasized that alcohol content is the most important consumer information on labels, and survey data shows only 4% of members have received consumer requests for nutrition details, compared to 29% for allergen information.

As alternatives, ACSA recommended allowing a simple calorie statement, using QR codes for expanded information, or incorporating details into the existing government warning. ACSA also stressed the need to align with FDA’s long-standing small business exemptions for nutrition labeling.

Read ACSA’s full comments on Alcohol Facts Statements

In response to Major Food Allergen Labeling for Wines, Distilled Spirits, and Malt Beverages (Notice No. 238), ACSA expressed general support for making allergen labeling mandatory. ACSA recommended simple, direct language such as “Contains: Nuts,” and urged TTB to allow all mandatory ingredient disclosures, including allergens, sulfites, and color additives, to be consolidated into a single statement for clarity. ACSA also supported TTB’s proposal not to require allergen statements for proteins that are eliminated through distillation and agreed that a five-year compliance period would provide small producers enough time to adjust.

Read ACSA’s full comments on Major Food Allergen Labeling