Moore, Barbara J. PhD
Today, most of adult Americans-an estimated 61.4% of those 18 years or older (see table 3.1 of Ref.1)-consume beer, wine, and distilled spirits at least occasionally. Alcoholic beverages are a quantitatively important source of calories for the 28% of US adults who drink more heavily.2 Alcohol-containing beverages are a significant source of calories in the diets of the 27.4% of men and 11.2% of women who describe their alcoholic drink intake as either "moderate" (3-14 drinks per week for men and 3-7 drinks per week for women) or "heavy" (>14 drinks per week for men and >7 drinks per week for women) (see Table 3 of Adams and Schoenborn1). Figure 1 describes the per capita consumption of alcohol-containing beverages as compared with other types of beverages in 2005. After soft drinks, which is the fluid product category most widely consumed (35 gallons per capita per year), the category that includes "beer, wine, and spirits" is next (21.3 gallons), followed closely by milk (21.0 gallons).
Figure 2 shows that of the 3 major types of alcohol-containing products, beer is by far the product most frequently consumed. The figure also illustrates that per capita consumption of alcohol-containing beverages has declined somewhat in the United States over the past 3 decades. Figure 3 shows how consumption of beer has changed since 1980 as compared to milk, soda and bottled water.
Although the Dietary Guidelines for Americans (DGA) 2005 acknowledges the beneficial effects of alcohol-lower all-cause mortality and lower cardiovascular disease mortality when consumed in moderation-the report alludes to the challenges of maintaining a healthy weight when beverage alcohol is consumed in excess.3 The DGA 2005 identifies the many health hazards of heavy drinking3 and the risk of accidents and injury as well as fetal malformations associated with "less than heavy" drinking.3 Consequently, the DGA takes pains to point out that it is not recommended that anyone begin drinking or drink more frequently as a health promotion strategy.
Requirements for Labeling Alcoholic Beverages
Because alcohol consumption is clearly related to human health, it may come as a surprise that alcohol-containing beverages are not regulated under the auspices of the Department of Health and Human Services. The federal agency responsible for carrying out the Federal Alcohol Administration Act governing the marketing, packaging, and labeling of alcohol-containing beverages is the Alcohol and Tobacco Tax and Trade Bureau (referred to as the TTB), which is part of the Department of the Treasury. The Treasury Department is not usually thought of as having a public health focus, and indeed, it is currently focused on buttressing the struggling US economy. Given the current economic crisis, the public health value of labeling alcohol-containing beverages may not garner the attention of Treasury Secretary Timothy Geithner or his staff.
The TTB does require 2 mandatory warning labels on alcohol products, one directed to pregnant women regarding birth defects and the other directed to drivers or operators of heavy machinery warning them about the intoxicating effects of alcohol. But the TTB can and should do more to inform and guide consumers toward responsible decision making regarding alcoholic beverages.
A Brief History
As early as 1972, the Center for Science in the Public Interest (CSPI) has petitioned the precursor agency to the TTB-the Bureau of Alcohol, Tobacco, and Firearms (ATF)-to require meaningful labeling of alcoholic beverages. As a belated response, the ATF issued a very weak rule in 1980 but then rescinded it in 1981. This led to a court challenge, after which the ATF decided to reexamine its stance on ingredient labeling. Then in 1983, the ATF went on record as rejecting alcohol labeling because, in the agency's view, "there was no overwhelming desire on the part of consumers for comprehensive ingredient labeling." Indeed, in the early 1980s, public awareness of the growing obesity epidemic was limited and the activist organization Mothers Against Drunk Driving had just been founded. Appreciation of how product labels can educate and guide behavior had not yet emerged, nor had consumer demands for full disclosure of ingredients (beyond the currently mandated sulfite content of wines) fully developed. Research was indeed needed to ascertain how consumers felt about more comprehensive labeling of alcohol-containing products.
The battle began again in 2003 when the National Consumers League, the CSPI, and 75 other organizations petitioned the TTB to require an easy-to-read, standardized "Alcohol Facts" label, similar to the popular "Nutrition Facts" labels on foods and nonalcoholic beverages. This time, the TTB's response was to issue draft specifications for a "Serving Facts" panel that would contain extensive label information, including the amount of alcohol per serving. Then, under intense pressure from certain segments of the industry, the TTB backed down again, deciding that any label changes must be done through a rule-making process.
In 2005, the TTB issued an advance notice of proposed rule making (ANPRM) asking for public comment on a range of issues related to the labeling and advertising of beverage alcohol.4 The ANPRM generated more than 18,000 comments, most of which, according to an analysis conducted by Shape Up America!,* supported a standardized label with the number of calories and the amount of alcohol per serving as well as standard drink information.
In 2007, the TTB issued a notice of proposed rule making on improved labeling of alcoholic beverages, stating that it was now appropriate to consider amending the regulations because of increased interest in including nutrition and ingredient information on alcohol beverage labels.5 The TTB also requested submission of consumer data relevant to the issue.†6
What Is a "Standard Drink"?
Except for specific subpopulations that the DGA 2005 states should not drink at all (those susceptible to alcohol dependency or addiction, women of childbearing age who may become pregnant, pregnant and lactating women, children and adolescents, individuals taking medications that can interact with alcohol, and individuals with certain specific medical conditions),3 the government's advice on alcohol consumption is couched in terms of "standard" drinks:
Those who choose to drink alcoholic beverages should do so sensibly and in moderation-defined as the consumption of up to one drink per day for women and up to two drinks per day for men… (DGA 2005)3
The common denominator behind this definition of a standard drink is 0.6 fl oz (14 g) of pure alcohol. Based on this amount of alcohol, a standard drink consists of a 12-oz bottle or can of regular beer (5% alcohol), a 5-oz glass of regular (dinner) wine (12% alcohol), and a 1.5-oz drink of 80 proof (40% alcohol) distilled spirits or liquor (either straight or in a mixed drink). The problem is that most Americans do not know how the government defines a "drink," and there is nothing on alcoholic beverage labels describing how many drinks are in the labeled product. Further compounding the problem, few consumers know what beer is "regular" or that "proof" describes the alcohol concentration of a beverage. Also, the definition of proof used in America differs from that used in the United Kingdom. In the United States, proof is a number that is twice the percentage (by volume) of alcohol, so an 80-proof liquor contains 40% alcohol by volume (ABV). But the ABV of beer, wine, and distilled spirits available in the US marketplace varies considerably, so adhering to the above serving sizes will not ensure that the alcohol delivery in that serving falls within the range of 0.6 fl oz.
To illustrate this point, in 2005, a different federal agency, the Federal Trade Commission (FTC), gathered together data on the ABV of a selection of beers, wines, and distilled spirits available in the marketplace and supplied this information to the TTB:
* Beers varied from 3.3% to 17.0% ABV7(ref 18)
* Wine ranged from 6.0% to 20.0% ABV7(ref 19)
* Distilled spirits varied from 8.0% to 75.5% ABV7(ref 20)
The FTC's position on the labeling of alcoholic drinks is relevant to this discussion. Although the TTB has jurisdiction over the labeling of alcohol-containing products, the FTC, an independent federal agency, shares jurisdiction with the TTB over the advertising of alcohol, and the 2 agencies cooperate with one another over matters that fall within their joint jurisdiction. For this reason, the comments of the FTC to the TTB regarding labeling are of great interest.
In a report to the TTB issued in January 2008, the FTC argued that "[b]ecause the alcohol and nutrients in beverage alcohol products can affect health, information about these ingredients can help consumers make better-informed decisions."7 The FTC supported the TTB's proposal to substantially increase the amount of information on alcohol labels, arguing that the provision of "nutrient content and health information to consumers may have a significant effect on the type and amount of health information they receive, which, in turn, may affect the products they purchase and use."7(p3) The FTC comments to the TTB highlight several important issues that should inform how the label is designed:
1. The FTC affirms the position of the TTB that the alcohol content of a beverage is "one of the most important pieces of information about that product"7(p6) but warns that this vital information "need not appear on the newly proposed Serving Facts label"7(p6) as the rule is currently proposed by the TTB. The FTC appears to imply that such information should appear on the newly proposed Serving Facts label, that is, should be mandatory.
2. The FTC warns that "[d]isclosure of alcohol content in fluid ounces per serving is not required by the proposed regulations, but it is permitted at the marketer's discretion."7(p6) The FTC goes on to state that the "…TTB's proposal is not likely to provide consumers with adequate information about the alcohol content of the products currently available on the market, insofar as it does not mandate disclosure of alcohol content in fluid ounces per serving for all beverage alcohol products."7(p6) Again, the clear implication is that the TTB should mandate that such information be disclosed.
3. The FTC recommends that the labels provide consumers with the standard serving size (ie, those described above by the DGA 2005) and the amount of pure alcohol (in fluid ounces) per serving so that consumers can "properly compare" beverages.
4. The FTC states that most Americans drink and that a significant minority binge drink. Accordingly, the FTC suggests that "[a] label may be an important tool to help consumers follow government recommendations on alcohol intake."7(p9)
5. The FTC suggests that consumer research be conducted that is focused on the appearance and content of alcohol labels to determine "the effectiveness of proposed disclosures, including whether certain descriptors are sufficiently prominent and made in a format that consumers can understand."7(p10) It was to this call for consumer research that we responded, by conducting the studies described in the balance of this article.
The National Consumers League commissioned an opinion poll of 1,042 adult Americans 18 years or older. Conducted in September 2005 by Opinion Research Corporation, the survey found overwhelming public support for major changes in TTB policy. Of those adults polled, 9 in 10 said that companies should be allowed to put information on their labels that will state how much alcohol is in a standard serving. The survey also confirmed public support for mandatory ingredient labeling, including information about ingredients that may cause an allergic reaction. Moreover, the survey documented widespread public support for requiring information about the alcohol content and the amount of alcohol per serving. According to the poll, 93% of the public said that information about the alcohol content would help them make better purchasing and consumption decisions and 87% said that they would favor including the amount of alcohol per serving on product labels.
To build on this preliminary research and to learn more about the possible design of such a label, in 2007, Shape Up America! commissioned a national randomized survey, conducted by Penn, Shoen and Berland's (PSB) Internet Surveys Group (ISG), to determine what kind of labeling information consumers would find most helpful. The ISG has access to more than a hundred million consumer e-mail addresses, which it uses to construct representative "pools" of respondents for studies. To ensure a reliable and accurate representation of the total national adult population, PSB ISG used a series of screener questions up front to control for important demographic factors including age, geography, sex,race/ethnicity, income, and education. These measures control for bias associated with online polls as compared with telephone polls. The margin error of the PSB ISG poll is ±4.4% at the level of the 95th confidence interval.
Conducted in December 2007, this online census-balanced sample of 503 adult Americans 18 years or older included 10 specific questions. The survey questionnaire is available at the Shape Up America! Web site (www.shapeup.org).8 Participants were presented with and asked to review 3 alternative label formats that were rotated randomly to control for order selection bias. Only 1 of the 3 labels (see Figure 4) represented the information proposed in the TTB's rule making, and the others (see Figures 5 and 6) included additional information as recommended by the FTC. The most complete label (see Figure 6) included information about the alcohol content of the product and information about responsible drinking consistent with the DGA 2005.
The survey findings confirmed that adult Americans want complete labeling information on alcoholic beverages, including the percentage of ABV, the serving size, the amount of alcohol per serving, the definition of a "standard drink," and the number of standard drinks per container. Eight in 10 of those polled (79%) agreed with the statement: "There is no point in having labeling on the containers of alcohol beverages unless labels include all nutrition and ingredient information, including the amount of alcohol in each drink."
When informed that the TTB was considering requiring mandatory labeling on all beer, wine, and distilled spirits products, 9 in 10 (90%) of those polled in 2007 said that they supported this action. As shown in Table 1, the level of support was high regardless of demographics, political affiliation, and alcohol usage.
As shown in Table 2, consumers also ranked "the amount of alcohol in each drink" as the top priority (92%) for required information on an alcohol label, followed by information about the calorie content (84%). Considered less important on the label is the amount of carbohydrates (75%), fat (71%), and protein (66%), although consumers also value this information.
The survey documented widespread public support for using alcohol labels to educate consumers about how to follow the Dietary Guidelines' advice on moderate drinking.
* When asked if they were familiar with the Dietary Guidelines for Americans, 60% of respondents replied affirmatively.
* Nearly 4 in 5 Americans (79%) said that it would be useful to know that the Dietary Guidelines define "moderate consumption" of alcoholic beverages as up to 2 drinks per day for men and up to 1 drink per day for women.
* More than 4 in 5 surveyed (81%) said that it would be helpful to know that the government defines a standard drink as containing 0.6 fl oz of pure alcohol, which translates into 12 fl oz of regular beer, 5 fl oz of wine, or 1.5 fl oz of 80-proof distilled spirits.
As explained above, only 1 label provided the information the TTB required. That label was not favored. Most respondents (76%) opted for label 3 (see Figure 6), the most complete label, which included calories, carbohydrates, fat, and protein along with the amount of alcohol per serving and the statement "a standard drink contains 0.6 fluid ounces of alcohol." In contrast, only 7% chose the label format consistent with that proposed under TTB's rule making. Preference was consistent across all demographic groups.
In 2008, the National Consumers League and Shape Up America! commissioned a follow-up telephone survey. Conducted by Opinion Research Corporation, the poll surveyed 1,003 adult Americans 21 years or older from April 11 to 14, 2008, to identify the information that consumers consider most important on an alcohol label. The top priority, cited by more than 3 in 4 respondents (77%), is listing the alcohol content followed by the amount of alcohol per serving (73%) and the calories in each serving (65%). Of less importance but considered valuable information is the following: the number of servings in the bottle or can (57%), the carbohydrates in each serving (57%), the amount of fat in each serving (52%), and the protein in each serving (46%). When asked about the TTB's proposal that fails to require information on the amount of alcohol in a serving on the label, 74% of respondents said that this information should be mandatory.
Taken together, these findings show that Americans want complete and clear information about what is in alcoholic beverages, starting with the amount of alcohol. The results suggest that consumers understand that complete label information is needed to permit product comparisons, calorie guidance for weight control, ingredient information about product formulations, and advice about moderate drinking consistent with the DGA 2005.
The issue of alcohol labeling has a long history spanning several decades. In 1972, consumer organizations asked the federal government to require meaningful alcohol labeling. In 2003, the National Consumers League joined with the CSPI and 75 other public health and consumer organizations to submit a formal petition to the TTB. This may have prompted the April 2005 ANPRM issued by the TTB as the Bureau considered various issues around labeling. In 2007, the TTB issued a notice of proposed rule making, which was a step forward but omitted the provision of clear guidance on alcohol content per serving on the proposed label. Given this long history and the current focus of the Department of the Treasury on the economy, the issue of alcohol labeling may not become a priority, despite its importance to consumers. It is difficult to know whether we should be optimistic whether alcohol labeling is imminent, but it is clear that consumers would welcome such labeling. Research shows that most adult American consumers do drink and they would prefer that calories and alcohol per serving plus all necessary information needed to follow the DGA 2005 recommendations for moderate drinking-no more than 1 drink per day for women and 2 for men-be included on the label on alcohol-containing products.
1. Adams PF, Schoenborn CA. Health behaviors of adults: United States, 2002-04. National Center for Health Statistics. Vital Health Stat
. 2006;series 10, no. 230.
4. Department of the Treasury, Alcohol and Tobacco Tax and Trade Bureau. Labeling and advertising of wines, distilled spirits and malt beverages; request for public comment. Fed Regist
5. Department of the Treasury, Alcohol and Tobacco Tax and Trade Bureau. Labeling and advertising of wines, distilled spirits and malt beverages; request for public comment. Fed Regist
7. Comments of the Staff of the Bureau of Consumer Protection, the Bureau of Economics, and the Office of Policy Planning of the Federal Trade Commission. Before the Department of the Treasury, Alcohol and Tobacco Tax and Trade Bureau: Labeling and Advertising of Wines, Distilled Spirits and Malt Beverages Notice No. 41. January 27, 2008. http://www.ftc.gov/os/2008/01/080128ttb.pdf
. Accessed August 21, 2008.
*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-96% of all the comments TTB received. There were 750 letters in opposition, approximately 4% of all the letters received. See also joint Shape Up America! and National Consumers League press release: http://www.shapeup.org/about/arch_pr/101205.php. Cited Here...
†Notice no. 73-Labeling and Advertising of Wines, Distilled Spirits and Malt Beverages (Serving Facts Labeling) Rulemaking Description: TTB proposes to amend its regulations to require a statement of alcohol content, expressed as a percentage of alcohol by volume, on all alcohol beverage products. This statement may appear on any label affixed to the container. Alcohol and Tobacco Tax and Trade Bureau also proposes to require a Serving Facts panel on alcohol beverage labels, which would include a statement of calories, carbohydrates, fat, and protein. Industry members may also choose to disclose on the Serving Facts panel the number of U.S. fluid ounces of pure alcohol (ethyl alcohol) per serving as part of a statement that includes alcohol content expressed as a percentage of alcohol by volume. The proposed regulations would also specify new reference serving sizes for wine, distilled spirits, and malt beverages based on the amount of beverage customarily consumed as a single serving. However, TTB is not defining a standard drink in this document. We proposed to make these new requirements mandatory three years after the date of publication of a final rule on these matters. Alcohol and Tobacco Tax and Trade Bureau proposes these amendments to ensure that alcohol beverage labels provide consumers with adequate information about the product. RIN 1513-AB07. Cited Here...
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