Comment on Non-Rulemaking Docket re: Labeling and Advertising of Wine, Distilled Spirits, and Malt Beverages with Alcohol Content, Nutritional Information, Major Food Allergens, and Ingredients (Docket No. TTB-2024-0002)

Background Center for Science in the Public Interest (CSPI) has a long history of engaging with TTB on this topic, starting in 1972 when CSPI first petitioned the Bureau of Alcohol, Tobacco, and Firearms (ATF, the predecessor to TTB) to require ingredient labeling.10 In 1993, the FDA11 and the U. [...] According to 2023 guidelines from the American Diabetes Association, people with diabetes are at increased risk of hypoglycemia during and after consumption of alcohol.58 This is in part due to alcohol inhibiting normal glucose metabolism59 and in part due to people overestimating the amount of carbs in their alcohol.60 Carb labeling on alcoholic beverages would likely help with the latter and pre. [...] Policies that increase the price of alcohol decrease alcohol consumption.95 Alcohol prices and taxes are inversely associated with alcohol-related morbidity and mortality including violence, traffic crash fatalities, and drunk driving.96 An increase in the price of alcoholic beverages could help those who drink better adhere to the DGA moderate drinking guidelines and lead to a reduction in alcoho. [...] Among the 42 beer brands and 1 wine brand with either a Serving Facts label, Alcohol Facts label, or Statement of Average Analysis, 42 (95%) provided a continuous line of text rather than text with line breaks for each separate piece of information (like the Nutrition Facts label), and most of the time the serving information had no border/box around it and was crowded next to other text, written. [...] Scientific Report of the 2020 Dietary Guidelines Advisory Committee: Advisory Report to the Secretary of Agriculture and the Secretary of Health and Human Services.