Submission Number: 00030
Commenter: Ahmed Siddiqi
Agency: Federal Trade Commission
Initiative: Proposed Consent Agreement In the Matter of Phusion Projects, LLC; Jaisen Freeman; Christopher Hunter; and Jeffrey Wright; FTC File No. 112 3084
Attachments: No Attachments
In response to the Phusion Projects proposed consent agreement, the Commission received well over 105 identical comments, and a representative copy of those comments is found below.
I respectfully request that FTC withdraw this agreement based on the lack of scientific grounding of its assumptions, as well as the lack of support from the public health community and other industry members, and ask that FTC instead propose a more effective solution to the following problems:
1. The apparent endorsement of 2.5 drinks as an acceptable single-serving size drink, ignoring current federal standards for one per day for females, and two per day for males.
2. The lack of scientific evidence that a label listing the number of standard drinks in one container will prevent drinkers from consuming the entire can at one time. Given the target market for these products, it's likely that such labeling will backfire and serve as a marketing tool.
3. The lack of scientific evidence that putting a resealable cap on a single-serving container will effectively discourage drinkers from consuming the entire can at one time. These are not half-gallon containers of milk or juice from which drinkers pour just one glass. These products are sold in convenience store coolers, intended for immediate consumption.
4. This proposed order does nothing to solve the fundamental problem with these products. The sweetened alcoholic beverages with up to 12% alcohol content will still be sold in 23.5 ounce containers.
Worse than taking no action at all, with this consent order, the FTC will undermine public safety and health