Comment 04110534

From: Margaret Pedersen [Margaret@testarossa.com]
Sent: Wednesday, August 24, 2005 1:50 PM
To: Rulemaking, TTB
Subject: 'TTB Notice No. 41'

Margaret Pedersen
Testarossa Vineyards
300-A College Ave.
Los Gatos, CA  95030 

I am writing to voice my concerns, as the CFO of a small, family-owned winery in California, regarding the ruling proposed by the TTB to impose including a food panel and ingredient listing on each and every wine bottle.  As a small winery, there is almost no industry segment that suffers under such a heavy burden of regulation and paperwork.  Adding these additional regulations will be a very costly burden to all small wineries, as the redesign of bottle labels not only is an expensive proposition, but the administration involved for label approvals and individual state compliance is onerous.

Wineries are required to have a bonded winery permit with the TTB and their state, file monthly inventory reports to the TTB, semi-monthly excise tax returns to the TTB, monthly, quarterly and annual compliance reports to any state that they ship wine into, some with the excise taxes as well, label approvals for each bottling that has a label change, label approvals sent to many states that wine is being shipped into, direct shipping permits, distributor permits, annual reports to the Department of Food & Agriculture, and now we have the Bio-Terrorism Act to deal with.  This is a huge amount of paperwork required to sell any amount of wine, from the tiniest of boutique wineries to the largest, multi-national corporations.

Also, wine labels are fairly small and already must include a standard Government Warning about the effects of alcohol and a sulfite statement.  If we are now going to be required to include a food panel and ingredients listing, we'll need bigger bottles to hold all the required statements.

In addition, I do not believe that consumers will benefit from a listing of the "ingredients" that are used in winemaking, as it is not equal to baking a cake.  Wine is not made of sugar, eggs and flour, but grapes that go through a chemical process to ferment and become wine.  The end product is wine  not grapes, yeast, acid, French oak barrels and time.  Providing the list of additions required to augment these processes will not benefit consumers.  
I am sympathetic to consumers wanting to have as much information as possible about what they are buying, but are consumers willing to pay for this?  I doubt it.