Comment 0419958

From: Wright, Gregg [GWright@imc.com]
Sent: Thursday, August 18, 2005 1:25 PM
To: Rulemaking, TTB
Subject: 'TTB Notice No. 41'

name=Gregg Wright
name=
Address1=610 N Oak St
Address2=
City=Falls Church
State=VA
Zip Code=22046
Comments=Speaking purely as a wine consumer, I would like TTB to minimze the number of mandatory statements and content on labels, particularly warnings.
You should take into consideration that there is a maximum amount of information that the vast majority of people will be willing to peruse on a label besides the essentials of the winemaker, varietal, AVA, and vintage.
The more fine print that is required--and you know it will be the smallest font size allowable--the more the label will look like these ridiculous instruction cards that come with consumer products: so much gobbledygook that you don't read a thing and chuck it out straightaway.

Too many warnings and minutia thus have the opposite effect of the intent behind including them: they overwhelm and as a result, aren't read. I will add that overdoing these warnings and (what is too casually presumed to be
helpful) information makes label content come across as a government nag-- to the point of being condescending like a old nanny. Going too far down this path will be certain to ultimately diminish TTB in eyes of reasonable consumers and reinforce the bureacratic stereotype it already verges on. The public does not need and does not want the overbearing, finger-waving rubbish as proposed by the CSPI self-proclaimed public interest group about how many drinks a day are considered moderate, etc. 

Whatever TTB ends up making mandatory, let the wineries put it into the tiniest type and relegate it to the bottom of the back label. Please let them minimize the clutter and eyesore effect this stuff causes. What the winemaker communicates on his wine lable is a small but important part of the wine consumer's experience with that wine; please minimize government intrusion in this regard.

I would liek to say that I do like the approach TTB has been taking on some topics that permits wineries at their option to make statements about product content, healthful benefits, etc. It should be the winery's choice to determine what is helpful and sufficient informational content, leaving the risk of overdoing it to them.