To: Virginia Alcohol Beverage Control Authority
From: Molson Coors Beverage Company Date: June 21, 2023
Subject: Response to Proposed Circular Regarding “so called crossover products”
Molson Coors Beverage Company (MCBC) appreciates the opportunity to offer commentary on the proposals contained in VABC Circular Letter 23-01. In all our endeavors, MCBC is committed to responsible marketing to legal-age consumers, avoiding consumer confusion, and working closely with authorities like the VABC to accomplish those objectives in the best way possible. With specific regard to alcohol variants of non-alcohol beverages (what the VABC considers one of many “so called crossover products”), brewers worked with the Beer Institute to develop industry guidelines for these products, including requirements that brewers differentiate product names, packaging, and labels and include warnings such as “CONTAINS ALCOHOL” in prominent locations. Further, brewers carefully ensure through compliance with the Beer Institute Advertising Code that any advertising and marketing of these products appeal primarily to legal drinking-age consumers and that alcohol variants are not linked to the selling and marketing of any non-alcohol counterparts. A link to the press release on the update to the Beer Institute advertising and marketing code can be found here: Beer Institute Revises Marketing Code to Address Alcohol Variants of Non-Alcohol Products – Beer Institute MCBC remains committed to working with our wholesale and retail partners in Virginia to ensure that all alcohol products in off-premise accounts are sold in appropriate spaces reserved for these products, although we fully agree that suppliers and wholesalers do not control retailers, are prohibited by law from doing so, and retailers alone make the final decision on where products are displayed in their stores. Retailers make the final decision on where products are displayed in their stores and, as such, MCBC supported legislation passed in 2023 to require signage. With that, we respectfully share the following observations for the VABC’s consideration. We welcome any opportunity to follow-up directly should the VABC have any questions or wish to discuss in greater depth.
Thank you.