The rules for wine require metric net contents, but allow supplemental
Customary at the moment (27 CFR 4.37b). TTB says in the proposals it allows
supplemental Customary on spirits and supplemental metric on beer, but the
rules don't explicitly say it. They would like to clarify.
The rest of the proposal eliminates standard sizes and allows metric fill of
any size for wine and spirits (any size Customary fill is currently allowed for
beer.)
I think the proliferation might get out of hand, but some of our standard sizes
are not well coordinated with EU standard sizes (wines are better than spirits
in this regard). At least a few additional sizes for better coordination with
the EU may make sense. However, I'm not sure I care enough either way to
submit comments.
On Thursday, October 24, 2019, 6:39:49 PM EDT, [email protected]
<[email protected]> wrote:
In the November-December 2020 "Metric Today," which will be disseminated
shortly by our USMA President, it is reported:
"The US Department of the Treasury, Alcohol and Tobacco Tax and Trade
Bureau (ATTB) is seeking public comment regarding the elimination of
certain standards of fill for wine and distilled spirits as well as the
amendment of malt beverage net contents labeling regulation. Under the
proposals, wine and distilled spirits would require mandatory metric on
all bottles and add optional US customary units."
The change allows "optional US customary units" which are now prohibited.
Did I get this right? Shouldn't we be pushing back hard on this
backsliding proposal?
Unfortunately, public comment ends very soon, on October 30, 2019. I have
appended below the direct URL to get to the notice page. Once there, you
can click the COMMENT NOW! button to enter your comment against this
backsliding.
Notice 182 and 183:
https://nam01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.regulations.gov%2FsearchResults%3Frpp%3D25%26po%3D0%26s%3Dnotice%252B182%26fp%3Dtrue%26ns%3Dtrue&data=02%7C01%7Cusma%40lists.colostate.edu%7C6221b51931c4478a655708d758e27dd4%7Cafb58802ff7a4bb1ab21367ff2ecfc8b%7C0%7C0%7C637075602107104152&sdata=M%2FohI0QdUHUDaxtcLtdvFmJc5MQdmW2UJ%2FrVgF5WvRY%3D&reserved=0
Could one of our knowledgeable writers could post here a brief template
for a response that we each could modify for a personalized comment?.
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