DISCUS: As TTB Considers Label Changes, It Will Need to Avoid Creating Consumer Confusion

Distilled Spirits Council of the U.S. said it looks forward to working with Alcohol & Tobacco Tax & Trade Bureau on possible new ingredient labeling requirements.  TTB recently announced it planned to issue an advanced notice of proposed rulemaking on ingredient labeling.

DISCUS expressed some concern that ingredient labeling might cause consumer confusion.  That's because the distillation process "itself transforms the raw materials used to make a spirits product in such a way that many of the ingredients, proteins, peptides or fragments, for example, are not carried over into the distillate."

An ingredient labeling rule could cause consumer confusion, DISCUS said, if it required including ingredients that went through the distillation process but aren't present in the final product.

DISCUS expressed confidence in the statement that TTB  "will carefully consider all information and input when considering changes related to ingredient labeling. The Bureau will want to carefully consider any changes so as to avoid any consumer confusion," DISCUS said.

The trade group noted that DISCUS Director Members recently announced a voluntary commitment to provide “Serving Facts” information for spirits products as part of the recent White House Conference on Hunger, Nutrition and Health. DISCUS’ support of the White House Conference and its stakeholder commitment was highlighted and commended by the CDC Foundation.