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  1. #1
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    New Scotch Labeling Rules Proposed

    I offer the following both because it is interesting in its own right, and to suggest maybe something of this sort would be a good idea for our own whiskey industry.

    Last week the Scotch Whisky Association (SWA) announced its proposals for revamping the laws regarding the categorization and labeling of Scotch whisky.

    The new SWA proposals are thought to be the most extensive in nearly a century.

    If the new proposals are adopted there will be only five legal definitions for different styles of Scotch: Single Malt, Single Grain (both from a single distillery), Blended Scotch, Blended Malt and Blended Grain. Definitions such as 'pure malt' or 'vatted malt' would be outlawed, both replaced by 'Blended Malt.'

    The proposed legislation also aims to outlaw the use of geographical descriptors for whiskies that are not from that area, such as 'Islay Cask Finish.'

    The proposals are currently before the Scottish Executive and the UK government, and the SWA hopes they will become law by 2007. There is likely to be a one-year grace period to allow sell-through of old stock.

  2. #2
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    Re: New Scotch Labeling Rules Proposed

    I would like to see the description 'straight' replaced by something that guaranteed the buyer that the contents of the bottle come from the same distillery.

  3. #3
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    Re: New Scotch Labeling Rules Proposed

    I would like to see the description 'straight' replaced by something that guaranteed the buyer that the contents of the bottle come from the same distillery.
    Obviously, the words "single barrel" provide that assurance, as do the words "bottled in bond."

  4. #4
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    Re: New Scotch Labeling Rules Proposed

    Obviously, the words "single barrel" provide that assurance, as do the words "bottled in bond."
    True, but they are not all-encompassing.

  5. #5
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    Re: New Scotch Labeling Rules Proposed

    Obviously, the words "single barrel" provide that assurance, as do the words "bottled in bond."
    True, but they are not all-encompassing.
    No, but they encompass what they encompass.

    For the most part, straight bourbons are the product of one distillery--probably 95% of the time--especially with the major brands.

  6. #6
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    Re: New Scotch Labeling Rules Proposed

    No, but they encompass what they encompass.
    Spoken like a true, original-intent, strict constructionist!

    (I hope that line seems as funny to me tomorrow as it does now, with three drinks under my size 44 belt.)

    Yours truly,
    Dave Morefield

  7. #7
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    Re: New Scotch Labeling Rules Proposed

    and to suggest maybe something of this sort would be a good idea for our own whiskey industry.
    What did you have in mind, then?

  8. #8
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    Re: New Scotch Labeling Rules Proposed

    Well, we have this anomaly where the number one American straight whiskey in the world seemingly exists outside the official standards of identity. I'd like to see that hole plugged. I agree with you that it would be nice to see a standard name for the product of a single distillery, for which "single" probably would do just fine. (No reason to redefine "straight.")

    One thing about the scotch rules that might be unconstitutional if the U.S. government tried to apply something similar to U.S. producers is that they give standard definitions for certain terms and forbid producers from using certain other terms, such as "vatted malt." That type of speech restriction might be illegal in the U.S.

    But this is a great place to open this dialogue. Come on, people, let's rewrite the standards of identity for American whiskey.

  9. #9
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    Re: New Scotch Labeling Rules Proposed

    I think things are fine as they are. As I argue in my letter to the editor in the last issue of Malt Advocate, imposing labelling rules like this (I was thinking of scotch whisky labelling) can, however unintentionally, result in a dampening of innovation. These rules can end up being hamstrings. The law is clear and protective enough today both in the U.K. and the U.S. I don't know if the full text of the proposed rules goes this far, but I don't see why (as I argued in my letter) a malt whisky producer should be restricted for example from using the distillery name to describe a vatted malt (or "blended malt" under the new lingo). Why not? If the owner wants to put the good name of the single whisky behind a vatted version and thinks the public will buy it, let him try. No one is harmed but this or misled. If they like the whisky they will buy more, if not, not. Only one of five names can be used (if the proposal is adopted) on a label for scotch whisky? Might that not be too restrictive? What if I make an all-barley malt whisky in a column still, is that a grain whisky or a malt whisky? Why can't I call that, "single malt grain" whisky? Why should I not be allowed to say, "Islay Cask Finish" if I put non-Islay whisky in an ex-Islay cask? Do all those Islay makers now age through to completion their whisky on Islay? If not, why can they call that whisky Islay whisky but the other guy who puts Speyside distillate in ex-Islay casks can't say Islay finish? Macallan just released a series of whiskies under its name that for the first time in decades are not exclusively aged in ex-sherry casks. Are we going to have rules too that would prevent the name Macallan from being applied henceforth to such a malt? I don't see the difference from the former cases bruited. I say, leave things as they are, things are working fine. Ditto in the U.S.

    Gary

  10. #10
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    Re: New Scotch Labeling Rules Proposed

    Geographical designations bug me, since there are no rules requiring producers in any given locale to adhere to a single style. But that means that consumers will, potentially, be misled.

    In the case of Scotch, the issue is most acute with regard to Islay distilleries: the archetypal Islay whisky is characterized by a very smoky, peaty flavor, and indeed Laphroaig, Lagavulin, Ardbeg, Caol Ila and Bowmore adhere to that model. But Bunnahabhain and Bruichladdich do not. Both are EXCELLENT whiskies, by the way; just not peaty like their neighbors. Yet they are labelled (accurately) "Single Islay Malt Scotch Whisky".

    Now, consider the uninitiated consumer, who has had and likes Lagavulin, but can't find any in his local store. (This is not far-fetched; the standard 16yo Lagavulin is in very scarce supply, but due to marketing of the "Classic Malts" series is arguably the most exposed of the Islay whiskies.) That consumer might well turn to another whisky labelled "Islay" but if he happens to grab Bruichladdich, he will not find that smoky character he is looking for.

    Brief aside rant:



    It infuriates me that Sam's has a card in their Scotch aisle recommending Bruichladdich to consumers who are looking for the absent Lagavulin. I love Bruichladdich; it's one of my favorite malts, but it is disingenuous bordering on dishonest to recommend it as an alternate for a Peat Monster like Lagavulin. But once a year or so ago I complained to one of their salesmen, who purported to be a whisky guy, about their characterization of Prime Malt No. 1 as having peat character (it's probably Bunnahabhain, and has no smoke to it at all), and he swore up and down that it DID have peat character, notwithstanding that I had actually bought a bottle and knew he was full of crap. I suppose I should not be surprised, since just about every time I have overheard a salesman there tell a customer something, it has included at least material omissions, if not outright false statements. So the moral of this story is, don't trust recommendations from the staff at Sam's.

    Perhaps they think they are educating or broadening the horizons of their customers by recommending non-peated whisky to people looking for Lagavulin, but they don't SAY that that's what they're doing. It's obvious that they are latching on to the Islay designation with no concern whatsoever whether whisky B tastes anything like whisky A, which the customer is looking for. They might as well recommend Auchentoshan or Macallan.

    [END RANT]

    To get back on topic, the same circumstance applies to American whiskey, in the form of the oft-debated "Tennessee Whiskey" designation. Jack Daniel's and George Dickel taste little if anything like each other (they are within the bourbon spectrum, but at different ends of it, I think), yet they are both labeled Tennessee Whiskey (and not bourbon). And to the extent the Lincoln County process separates them from bourbon (it is not my intent to reignite that topic here), in theory someone else could employ that process to filter bourbon but if it was made in Kentucky or elsewhere it could not be called Tennessee Whiskey, notwithstanding that it might closely replicate the character of Dickel or JD. So how does that designation help the consumer? I know it helps JD in its marketing, but that's no justification.

    There is nothing wrong with indicating where a whiskey is made, but that designation should not be a CATEGORY of spirit, unless there is at the same time a rule as to the type of spirit to which the designation may be applied. This is not a new idea to anyone who is an afficionado of French wine: "appellation controlee" or however it's spelled. I have a friend who's wife's family has a winery in the Loire Valley of France, and although they are located in the town of Chinon, one of the finest products of their winery can't be called "Chinon" wine, because it is not made according to the strict requirements for use of that designation.

    I am not advocating that; I think a distiller should be able to produce anything they want, but it should be labeled in such a way that a consumer can reasonably expect two products called the same thing to be generally the same type of spirit. I think that's pretty much true of bourbon, but is not true of single malt Scotch, and is not even true of Single Islay Malt Scotch, a relatively small category. (Much less Single Island Malt Scotch, a category encompassing such diverse drams as Arran and Talisker.)

 

 

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