The Virginia Spirits Association (VSA) thanks the Virginia Alcoholic Beverage Control Authority (VABC) for its continued efforts to engage with industry on issues of importance to the Commonwealth of Virginia and the spirits industry. VSA remains committed to the responsible marketing and use of spirits products.  In that vein, VSA asks that the proposed changes to 3VAC5-40-20 regarding labeling of products align with The Alcohol and Tobacco Tax and Trade Bureau (TTB)’s regulations for Alcohol Beverage Labeling and Advertising for labeling by referencing the same in the Virginia Administrative code. The mirroring of TTB’s code would provide a cost savings to both the Commonwealth and industry by a reduction in product labeling production by industry and approval hours required at VABC by the production and approval of a single product label for national distribution.