Brewers Association Weighs in on Potential Federal Labeling Regulation Changes

From allergens to calorie counts, major changes could be coming to craft beer labels in the future. The Alcohol and Tobacco Tax and Trade Bureau (TTB) began a multi-year project to revise mandatory disclosure rules for all products under the bureau’s jurisdiction, including beer, in February. Alcohol content, major allergens, nutritional information, and ingredients are some of the information that would become standard on beer labels. Making these disclosures required would put the consumer information standards for alcohol on par with those for food.
In a post discussing the proposed new regulations, the Government Affairs wing of the Brewers Association describes them as both an opportunity and a risk for small and independent craft brewers. “[W]e generally support the disclosures under consideration as they convey information important to certain consumers…[but] any new labeling rules should not disproportionately impact small businesses or suppress innovation and creativity.” The positives for consumers are obvious: more disclosures allow consumers to make more informed decisions, and for people with severe allergies they could be a matter of life or death. The drawbacks to the new regulations mostly have to do with the cost of label redesigns and testing alcohol and nutrition information.
The BA also proposes a few ideas for the legislation, such as making nutritional information available via QR code rather than taking up “valuable label ‘real estate'”. Another suggestion is an exception or modification to the new regulations for small-batch products so that testing is not required. Finally, the BA encourages the TTB to set a single effective date for the new requirements rather than gradually adding them to reduce printing costs and redesigns.
The TTB has already held two public listening sessions regarding the proposed mandatory disclosure rules and is gathering written comments until the end of April. Publication of the proposed rules would be the next step in the process, likely followed by a two-to-three year phase-in period. On that timeline, the new regulations would not become legally binding until four years from now.