Magazine article The Alcoholism Report , Vol. 17, No. 8
NCA Urges Bolder Warning Labels
The National Council on Alcoholism (NCA) charged that the regulations issued by the Treasury Department's Bureau of Alcohol, Tobacco and Firearms (BATF) implementing the new warning label requirement for alcoholic beverages "circumvent the spirit of the law by allowing alcoholic beverage producers broad latitude at the clear expense of alcoholic beverage consumers and the public's health."
In comments filed in response to the Feb. 16 temporary rule issued by BATF, NCA, through its Washington Office, said the BATF requirements "represent the lowest common denominator of compliance with the law."
In its rule, BATF proposed to allow placement of the warning on the front, side or back labels of the containers, providing that it is "separate and apart from all other information, readily legible and on a contrasting background." The agency said this would provide "flexibility" to producers of alcoholic beverages.
BATF proposed two type sizes. For containers with less than eight fluid ounces, the minimum type size would be one millimeter -- about as thin as a dime. For containers of more than eight fluid ounces, the minimum type size would be two millimeters.
"The intent of the Congress in enacting warning label legislation was clear: to provide consumers with specific health and safety messages about the risks associated with alcohol use in a prominent and conspicuous place on alcoholic beverage containers," wrote Christine Lubinski and Susan Galbraith, NCA Washington Representative and Assistant Washington Representative respectively. "The regulations under consideration thwart the intent of Congress in a number of key ways."
Among other criticisms, NCA said the "type size is too small, particularly for larger alcoholic beverage containers." It recommended the adoption of an additional category of type size of at least 4 millimeters for containers larger than 750 ml.
"It is regrettable that the regulations establish only two type sizes, given the wide size ranges of alcoholic beverage containers," NCA said. "The large number of alcoholic beverage containers which hold more than 750 ml certainly merit the establishment of another category type size. BATF had only to look at health warning labels on cigarette packages for an adequate model for health labeling. Instead, BATF's deference to the type size required for other information on alcoholic beverage containers minimizes the importance of consumer access to this basic health and safety information. Type size like other stipulations in the regulation appears determined by industry ease in compliance rather than the public's right to know."
NCA also was critical of BATF's proposal to allow placement of the warning on the front, back or side of the container, contending this "deprives consumers of consistent and prominent placement on the front label." NCA recommended that the warning be required on the front of the container.
BATF failed to provide guidelines on "appropriate, easily ligible type faces" for the warning statement, according to NCA, which said this failure "thwarts Congressional intent for a uniform health message and leaves the door open for indecipherable labels. …