New Scotch Labeling Rules Proposed

[cowdery]

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.

[Hedmans Brorsa]

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.

[cowdery]

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."

[Hedmans Brorsa]

Obviously, the words "single barrel" provide that assurance, as do the words "bottled in bond."

True, but they are not all-encompassing.

[cowdery]

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.

[bluesbassdad]

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

[Hedmans Brorsa]

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?

[cowdery]

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.

[Gillman]

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

[chasking]

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.)

[cowdery]

Well argued, and the point that labeling regulations should benefit the consumer is well taken.

Subscribers to WHISKY Magazine will notice that Dominic Roskrow has used his editor's column this month as a bully pulpit to address this issue, and he too makes some great points. Among them, he argues that applying the word "blend" to a beverage that is all malt whisky actually creates confusion about something that is now pretty well understood, which is that at least in the context of UK whiskies, "blend" always means a whisky that contains both malt whisky and grain whisky. He argues that moving that "fence" separating all-malt whisky from malt-and-grain whisky does a major disservice to consumers.

But I think, Chuck, that you left something very important out of your essay. If one likes and cannot find Lagavulin, what is the best alternative?

[Gillman]

We have to be careful of allowing trade associations to set in stone, albeit for the consumer's benefit, rules of almost any kind, even those that designate how a product should be made. Why should there be appellation rules? There should be minimum standards, e.g., you shouldn't call "wine" something made from other than grapes, I think that's fair. And obviously there need to be basic rules about what is "whisk(e)y" and what isn't; we have those rules. I was surprised Diageo didn't push back harder when it was suggested last year that it shouldn't call its new vatted malt, "Cardhu". I had to laugh about that one. 25 years ago no one (almost) heard of or cared about the malts, now they are such a sacred cow their name can't (so went the argument) be extended for use on a vatted version? Please. But think about it, if you can call your grain distillate on a label by only one of 5 names, does that make it easier to launch a new cereal distillate product that doesn't quite fit that labelling scheme, or for a new entrant with a cool but unorthodox idea to get into the biz? Not really. I am not saying that is what is intended here, I honestly don't think that is the case; rather, it is I think an instance of over-meddling, an attempt to establish order and regulation where none is needed. Dominic is right as is Chuck #2 of Chicago. In my opinion.

Gary

[chasking]

But I think, Chuck, that you left something very important out of your essay. If one likes and cannot find Lagavulin, what is the best alternative?

Short answer: Ardbeg.

Long answer: That's sort of tough to answer because nothing else is really like Lagavulin---it's heavily peated but it is also a very full-bodied whisky. The other whisky that comes to mind with those characteristics is Laphroaig, but Laphroaig has a very distinctive, can't-confuse-it-with-anything-else flavor, and it is quite possible to like Lagavulin but hate Laphroaig, notwithstanding that they are both peaty Islays---indeed, the distilleries are right next door to each other. The same rationale would apply to Bowmore, which to me doesn't seem to have quite as much smoke to it anyway. The other Peat Monsters, Ardbeg and Caol Ila, are lighter whiskies, but both are nonetheless very good, and they don't have a house style that hits you over the head the way Laphroaig and Bowmore do. I'd give the edge to Ardbeg. So, if you like smoky Scotch and can't get the Lagavulin you prefer, I would recommend Ardbeg (or, barring that, Caol Ila) because it's a good, smoky Scotch that is less likely that the others to be objectionable based on the "house style".

Other options include Longrow, a peated whiskey from Springbank, and Connemara, a peated malt from Ireland, but I haven't had either of those recently enough to opine on how similar they are to Lagavulin or the other peated Islays. There is also of course Port Ellen, but that distillery has been closed for over 20 years so the remaining bottles are getting pretty dear.

[Gillman]

As a fan of some Islays and whiskies in its style, I'd like to add that a peated malt, McCarthy's, is made in Oregon that is, I am sure, available at Sam's or Binnie's. It is somewhat older I understand than the stated 3 years of age. It has a good smoky character.

I second the suggestion about Connemara but stick to the cask strength. It costs more but unlike the regular issue (which is still pretty good) it uses no caramel coloring and in my view is better off for it. However it doesn't have Islay iodine, just rich clean smoke and a distinctive "cereal" note. This is a true (Scots-style) single malt, not an Irish pot still.

Regarding the other Islays mentioned, Ardbeg is the best bet but still rather different. It has that lemon skins taste which is unique. The 10 year old is a (relatively) good value. The 17 year old is not that peaty though, so don't buy that thinking it will resemble Lagavulin 16, it does not.

I am not really a fan of Caol Ila which to me has a cigaret ash-like taste. I have had numerous ages and they all taste like that to me. Just not my taste.

Laphroig is very good, but again quite different, more iodine, more salt, very assertive in taste.

Bowmore always tastes fern-like to me, the smoke is there but that sandy peat they use is in evidence.

I don't fancy much the other Islays that are available except Port Ellen but as mentioned it has not been produced for many years and surviving bottles will cost.

Tip: some Islays are available which do not identify the producer, e.g. as part of a well-known regional series (Lowland, Highland, Islay, etc.). This is true single malt and you'll see them for sure at Sam's. This can be very good, and good value, oh I remember the trade name they use now, McClelland. Someone once told me their Islay is young Bowmore well, if so, I like Bowmore young. Very good whisky. To make a Lagavulin, add some of that to any good aged Speyside, you'll get close.

Speaking of whisky I had a 10 year Edradour (rare house bottling) recently: wow, it has that knitted nougat-like taste I like, the sherry tastes are brown and rich not "ruby port" like some sherry casks seem to taste.

GAry

[clayton]

Nicely put, chasking.

I've found that both the Ardbeg 10 and the Bowmore 17 have strong appeal to anyone interested in peaty Scotch. They are what I pull off the shelf (instead of Laphroaig) when I ask what they'd like and they say, "Well, I like Laphroaig." (That is, unless I say, "Well, maybe you should try some good bourbon...")

[chasking]

Tip: some Islays are available which do not identify the producer, e.g. as part of a well-known regional series (Lowland, Highland, Islay, etc.). This is true single malt and you'll see them for sure at Sam's. This can be very good, and good value, oh I remember the trade name they use now, McClelland. Someone once told me their Islay is young Bowmore well, if so, I like Bowmore young.

Aha! That reminds me: Signatory Vintage Islay, in its 80 proof incarnation, is (at present, anyway) Laphroaig, but not too long ago they did a cask strength version that I am pretty sure was Lagavulin: 116 proof and 5 years old, it was a different animal from the standard 16yo, but quite good. You may still see this on a shelf somewhere, although it's done as far as Signatory is concerned (a rep at an in-store tasting told me it was NLA). I got several bottles at a Binny's last fall, so it's not long gone.

Enjoy your young Bowmore; for my part, I find Charles Shields' comment on maltwhiskey.com accurate:

<font color="blue">A young Bowmore can put a strong man off spirits. The briny, medicinal, phenolic character may taste like sucking on an old band-aid to the uninitiated, but add some age and those same characteristics soften and become the stuff of legend.</font>

But if it works for you, great!

Chuck King

[chasking]

Oh, and a note about this:

I am not really a fan of Caol Ila which to me has a cigaret ash-like taste. I have had numerous ages and they all taste like that to me. Just not my taste.

I've had that same experience with Caol Ila bottlings from Signatory, but on a trip to Scotland in '03 I picked up a bottle of the "official" Caol Ila 12yo, and it was better, although it was less smoky than the Signatory 11yo I got here. The Caol Ila distillery bottlings are now being sold in the States (I saw 12yo and 18yo at Sam's recently).

[Gillman]

Hey if you like 4 year old straight rye you'll like anything.

Gary

[Gillman]

Yes we have those two in Ontario, too, I was afraid to try them based on two 25 year olds I had from merchants. Can't recall who at this stage, but that taste seemed so characteristic I think I'll stay away.

What do you think by the way of the new Macallans? I find them disappointing, I've had the 15 and 18 year olds, haven't had the 21. I really was surprised Macallan, for this new series, moved away from all-sherry cask, never did I think they would do that.

Gary

[chasking]

What do you think by the way of the new Macallans? I find them disappointing, I've had the 15 and 18 year olds, haven't had the 21. I really was surprised Macallan, for this new series, moved away from all-sherry cask, never did I think they would do that.

Actually I haven't tried Macallan in a while because I don't usually like whisky with such a strong sherry influence. If they're using non-sherry casks now, I may have to check them out again!