The Virginia Beer Wholesalers Association generally supports the proposed amendments to the Product Labeling standards.  However, VBWA and its member wholesalers urge the Authority to consider implementing procedures to bring greater transparency to the label review process and appeal procedures. 

Many, if not most, suppliers are designing labels for national distribution, and the ability for a label to receive prior approval from the Authority before the product is introduced nationally would be far less costly than mandating changes to an already-existing label to meet Virginia’s standards. 

In addition, the VBWA urges the Authority to make it clear to the alcoholic beverage community that the changes to label approval proposed are proactive, and will not be enforced against those labels that already have been approved and are presently marketed in Virginia.

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.