Wine Institute opposes allowing retailers to fill growlers with wine, as this practice 1) dilutes brand identity, 2) negates winery expertise regarding how and when to bottle wine, 3) creates opportunities for public health and sanitation risks from retailers breaking original manufacturer packaging, and 4) exposes wineries to product liability for wine and containers that are unsafe for human consumption.  Because of this, we supported the distinction in Virginia Chapter 404 of the 2015 Acts of Assembly between the size growlers that retailers could fill for wine and for beer.  We supported maintaining smaller containers (less than 64 oz.) for wine growlers, as the prior law permitted.  We also strongly support the labeling requirements (manufacturer name, place of production, net contents in fluid ounces, and name/address of selling retailer) imposed on gourmet licensees, and would like to include the vintage and percentage of alcohol by volume information that is required on wine bottle labels.  More importantly, the health and safety implications of such labeling are not limited to gourment licensees; Wine Institute strongly encourages ABC to further amend the regulation to extend labeling requirements to ALL retail licensees that are permitted to fill wine growlers.  We also encourage ABC to adopt regulatory language clearly noting which entity (retail licensee or consumer) has responsibility for cleaning the growler prior to it being filled with wine.   Thank you for considering our concerns.

Terri Cofer Beirne, Wine Institute Eastern Counsel