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today is not prohibition, but prudence. The enemy is not drinking, but problem drinking; alcoholism and alcohol abuse, excessive or inappropriate drinking that causes problems in health, at work, on the highway, with the law and within families."

We believe that the dissemination of accurate, unbiased and comprehensive information on alcohol misuse, can best take place when the atmosphere of moralism surrounding this warning label proposal is abandoned. In its place we hope to see a growth of commitment to programs that aid personal choice based on understanding of factual information. The cooperative energy of many social forces is essential if we are to make what is known about healthful living practices genuinely useful to the American people, while preserving freedom of choice and an emphasis on individual responsibility.

Sincerely,

John A. De Luca

John A. De Luca
President

Wine Institute

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Thank you for your correspondence of June 4, 1979. A very
hectic schedule here at the winery has delayed my response
to your letter.

As the oldest continuous grape growing family, under the
same family name since 1878 including 5 generations, we
can give America and your community an objective view point.
I feel that by and large the potential public benefits from
legislation such as S. 440 can be very great indeed, and
I must congradulate your subcommittee on successfully put-
ting a problem which has concerned many of us for some time
into workable legislative form. I strong feel that this is
a long overdue step in the right direction, and that the
best way to reduce, if not eliminate, the abuse of alcoholic
beverages is to actively encourage responsible consumption
through a progressive education of the consummer. Your
subcommittee has, I believe, correctly perceived warning
labels as the most practical means of achieving this end.

As no doubt you are aware, I have been including such a
warning label on my wines for the past two years. I have
enclosed several representative samples.

100% New York State Estate Bottled Vintage Varietal Wines and Champagnes

Buyer reaction to these labels has been quite positive. On the whole, we have not experienced any problems by offering this bit of "advise, and the public has seemed to genuinely appreciate our concern along these lines.

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In response to your questions:

1. I firmly believe that warning labels, reasonably applied and sensibly worded, are very effective in educating the alcohol-consuming public. As are my own labels.

2. I do not believe that there is any necessity, or indeed value, in addressing the specific (and often uncertain) dangers of alcohol consumption. Our objective must be to increase awareness, not frighten or threaten.

3. A rotating label system is unnecessary and unpractical. Federal and State label regulations requiring label approval for all changes in label content would make the administration of such a regulation needlessly confusing and burdensome, both for alcohol producers and the B.A.T.F.

4. Beers and wines should definitely be included in such regulations. A brief trip to any local tavern will readily testify that both beer and wine could be subject to careless and irresponsible us by uninformed citizens.

5.

Major multi-international groups are the last of the economic blocks which could care about responsible awareness to the public which permits them to exist. Especially foreign companies doing business in the U.S.A.

6. Percentage alcohol by volume is of course already required in certain instances in the wine industry. A11 alcoholic beverage labels should include a list of practical materials used in the product, not the least of which is alcohol.

7.

Advertisements should also include warnings consistent with those which appear on the product's label. Further, it might be worthwhile to consider regulations for national television advertising of all alcoholic beverages. Even stronger, no alcoholic beverage should be allowed to advertise on national television or be promoted as a product which will enhance one's health, sex life, etc.

8.

Competitive advertising of alcohol beverages is totally

redundant.

I have also enclosed my brochure, perhaps the most progressive and definitely the most controversial publication of its kind in the industry.

If I can be of any further service. please do not hesitate to contact me.

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"This fine, limited edition, estate-bottled vintage wine was produced on Bully Hill by Hermann J. Wiemer, our winemaker. The grape varieties used to produce this peerless European taste were created in France in the late 19th century, and were introduced to this excellent viticultural region in 1946."

This wine is produced from Seyval and Aurora grapes. 100% of the grapes used have been grown and bottled on the property of the vintner. U.S. Government regulations permit the amelioration of wine with specified amounts of water and/or sugar, and permit the addition of spe cified amounts of grape brandy, alcohol or fruit-flavor concentrates to wine. Bully Hill wines are made without the addition of water, brandy, alcohol or fruit flavor concentrates. Pure cane sugar is added when neces sary to balance the wine during fermentation/processing.

WINE CRYSTALS

Federal regulations permit the use of the "ion exchange" process to
reduce cloudiness or precipitation. Because we do not use the ion
exchange process in winemaking, you may notice tasteless natural
potassium bitartrate crystals on the cork. We consider these nat-
ural crystals to be a sign of a quality wine. "Check the cork."

Winemaking at Bully Hill is guided by my belief that a product is truly
an extention of a person's soul, and I have dedicated this wine to the tradi-
tions of honesty and integrity in winemaking. These wines are the result
of my family's efforts and the efforts of those who work with me at Bully
Hill, and are available because you, the public, permit us to exist. For
complete information about what is in the wine and how it is made, please
write for our free brochure.

The woodcarving on the front label was done by the artist who can.
not use his name in block print.

WARNING: Even though wine has been used by humans for over
2,000 years, irresponsible use of this product could be harmful.

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