By Jack Becker
A few years ago, a Bill of Health post titled Jelly Beans, Booze, and B-Vitamins proposed fortifying cheap wines, hard liquors, and malt liquors with thiamine (vitamin B1).
The post suggested this as a public health measure to prevent Wernicke-Korsakoff syndrome (WKS) in the homeless alcoholic population. Wernicke-Korsakoff syndrome is a debilitating neurological disorder caused by thiamine deficiency. The disorder is significantly more prevalent in those with chronic alcoholism (up to 80% of whom become thiamine deficient), and it’s preventable by boosting thiamine consumption. For this reason, advocates started promoting the idea of fortifying cheap alcohol with thiamine decades ago.
Jelly Beans, Booze, and B-Vitamins explains that this initiative is complicated by the fortification policy put forth by the U.S. Food and Drug Administration (FDA), under which the agency does “not consider it appropriate to add vitamins and minerals to alcoholic beverages.” (While FDA and the Alcohol and Tobacco Tax and Trade Bureau [TTB] share jurisdiction over alcoholic beverages, TTB has followed FDA’s public health expertise in the past and would likely do so in this situation as well.) FDA similarly discourages companies from fortifying snack foods to avoid misleading consumers about their health value.
While the thiamine-in-alcohol proposal hasn’t gotten far enough to warrant official consideration, there’s a new fortified alcohol product making waves in the market. And while the stakes aren’t quite as high, it’s still a hard issue — a hard seltzer issue.
Vizzy Hard Seltzer
In December 2019, Molson Coors (at the time MillerCoors) announced its Vizzy hard seltzer product. Molson Coors differentiated Vizzy from other hard seltzers by being the first to include acerola cherry, “the superfruit high in the antioxidant vitamin C.” A clever advertising campaign ensued. In Vizzy’s commercials, actors had to choose between several identical things (houses in one commercial, video game characters in another, and dog show participants in a third). When they learned that one option included “antioxidant vitamin C,” they chose that option. After all, if the choices are otherwise identical, why not go for the one with a little extra vitamin C?
This advertising campaign, along with equally creative marketing including a Vizzy-themed (and scented) swimwear line and a Vizzy lottery for travelers facing holiday delays, has worked. Vizzy was the fourteenth fastest growing brand in 2021, putting it below TikTok but above Pfizer and Bitcoin. In under two years, it became the fourth most popular hard seltzer in the U.S., marking its success in a multi-billion dollar beverage category that’s projected to continue skyrocketing.
With box and can labels that prominently display “WITH ANTIOXIDANT VITAMIN C,” Vizzy is riding the consumer health and wellness wave. Though Vizzy led the charge in adding vitamins to hard seltzer, hard seltzer’s association with health and wellness precedes the brand. In fact, the rapid growth of hard seltzer is attributed to consumer perceptions of hard seltzer as a healthier beverage option than traditional high-calorie drinks. Not to be outdone, Vizzy also promotes that it is low in calories, carbs, and sugar. And even before the hard seltzer craze, alcohol brands rolled out health-focused products like protein-infused vodka. Vizzy is just a new, and massively successful, iteration of this trend.
But what about that FDA policy on fortification?
Trouble in Hard Seltzer Paradise
In the domain of fortification, alcoholic beverages are prime candidates for scrutiny. The 2020-2025 Dietary Guidelines “does not recommend that individuals who do not drink alcohol start drinking for any reason.” In addition to lacking nutrients, alcohol consumption can cause an abundance of negative health effects and increase public health/safety risks (such as car crashes, sexual assaults, and homicides). There is clear justification to disincentivize alcohol consumption, and even clearer justification to avoid incentivizing it.
In March 2021, the Center for Science in the Public Interest (CSPI) and the Consumer Federation of America (CFA) sent a letter to FDA asking the agency to take enforcement action against Vizzy for its vitamin C claims. The organizations stated that alcoholic beverages are not healthy and that fortifying them goes against FDA fortification policy. Importantly, the letter also notes that they believe Vizzy’s dried acerola juice was added for fortification and marketing, not for its preservative properties. CSPI and CFA concluded that Vizzy, and any other alcoholic beverages making claims related to fortification, are “misbranded” under 21 U.S.C. § 343(a).
Consumers subsequently filed class actions in Illinois and California claiming that Vizzy’s vitamin C and antioxidant claims are misleading. These lawsuits make claims similar to CSPI and CFA, arguing that Vizzy suggests its product is healthy when it’s actually harmful and definitively not healthy. It’s unclear whether these lawsuits will stunt the growth of Vizzy. But even if they do, Vizzy’s rapid growth and profits so far may justify its labeling decision as a shrewd, albeit morally ambiguous, business move.
Does Vizzy Deserve the Hard Treatment?
How much criticism should Vizzy face for its labeling and marketing practices? The beverage clearly violates FDA’s stance against fortification of alcoholic beverages. However, the agency’s underlying rationale may not be a perfect fit here. FDA has two goals in advising against the fortification of products like snack foods and alcoholic beverages: (1) prevent consumers from substituting fortified foods/beverages for naturally nutrient-dense foods/beverages; and (2) prevent the public from believing that certain fortified foods/beverages are healthy.
And so the question is, how does Vizzy’s labeling and marketing affect consumers and public perception?
Based on its advertising, the product’s main goal is to attract consumers away from other (nearly identical) hard seltzers. If this is the case, then consumers are just substituting Vizzy for other hard seltzers, not for naturally nutrient-dense foods/beverages like oranges. And for the public perception aspect, if the public already associates hard seltzers with health, then the addition of vitamin C might be a drop in the well(ness).
But until Vizzy can empirically prove that it deserves an exception (or that it uses acerola juice for non-fortification purposes), it seems wise to stay on the side of caution and discourage its labeling and marketing practices. Public health officials wouldn’t want to encourage any uptick in alcohol consumption, and they certainly would not want to incentivize the development of alcoholic multivitamins by allowing this.
Plus, even if it turns out that Vizzy isn’t doing anything bad for public health, FDA’s “rational fortification” principles require that fortification has a productive purpose, like correcting a dietary insufficiency. While vitamin C deficiency is rare in the U.S., people do still get scurvy. However, the probability that Vizzy’s wellness-loving consumer base overlaps with those at risk of developing scurvy seems low, and so Vizzy’s fortification does not seem “rational.”
Whatever the brand’s fate may hold, this might be the most excitement we’ve seen in the vitamin C market since 1983.
