Scotch whisky proposals – Association puts its case
In an industry as passionate as ours, you expect strong views. The danger is that hasty judgements can be made when not in possession of all the facts, as has occurred on the proposed Scotch Whisky definitions and labelling rules. So what exactly is being considered and why?

The proposals emerged after 12 months of careful consideration by a Working Group of senior industry representatives from Allied Domecq, Chivas Brothers, Diageo, Glenmorangie, Morrison Bowmore, The Edrington Group, William Grant, and Whyte & Mackay.

They, in turn, consulted colleagues at home and overseas as the proposals were shaped, leading to the package securing unanimous support within the SWA Council, which represents the vast majority of distillers and brand owners. Far from a knee-jerk reaction, the proposals emanate from the most comprehensive consideration of what Scotch Whisky is since the 1909 Royal Commission. These proposals are intended for legislation not a Code of Practice.

Until now, category descriptions have been dictated by convention. This has led to a wide variety of descriptions being used on labels; with, for example, both Single Malts and Blended Malts described as Pure Malts.

To prevent consumers being confused, and provide clear information, it is proposed the different categories should be formally defined and that it should be compulsory to use the appropriate category name as the sales description on every bottle sold.

The categories being proposedare Single Malt Scotch Whisky, Single Grain Scotch Whisky, Blended Scotch Whisky, Blended Malt Scotch Whisky and Blended Grain Scotch Whisky.

While the definitions themselves reflect traditional practice and are uncontroversial, there has been debate regarding the term Blended Malt Scotch Whisky.

Several alternatives were considered, with Vatted Malt the first possibility. However, although used in the trade, that description has seldom been used on labels – industry experience is that consumers don’t understand the term and find it unattractive due to its industrial connotations.

The term Pure Malt was also rejected. Some believe Pure Malt and Single Malt are the same thing; others that Pure Malt is a superior or separate category; and few appreciate that many Pure Malt brands have been blends of Malt Whiskies. Given this, it is proposed to ban the use of the description ‘Pure Malt’, in that combination, from labels.
Thus, after considerable discussion, consumer research, and soundings with distributors worldwide, it was agreed that Blended Malt Scotch Whisky best described the product.

We believe it is a pragmatic choice as on plain reading, without preconceived notions, Blended Malt Scotch Whisky clearly indicates to the consumer there is more than one Malt Whisky in the product. Blending is a well understood concept and the description is also compatible with EU law under which any combination of Malt Whiskies is already legally a ‘blend’.

Clearly, there is no point in requiring the category name to be used if it appears on packaging where it cannot be seen. Rules are therefore proposed to ensure the compulsory description appears prominently and consistently on packaging. Repeated use will bring clarity and help consumers identify the different categories.

While there has been an inevitable focus on the category names, it is also important to stress that a broad package of proposals is being brought forward, and brief details of which we give here.

Additional protection is proposed for traditional regional names, i.e. ‘Highland’, ‘Lowland’, ‘Speyside’, ‘Campbeltown’ and ‘Islay’. It is also proposed that a distillery name should not be used as a brand name on any Scotch Whisky which has not been wholly distilled in the named distillery. Consideration is, however, being given to protection of existing brands.

From the enquiries we receive, it is clear that action is also required to prevent misleading marketing of Single Malts. A provision has therefore been drafted to stop Single Malts being sold under labels which mislead as to where the Single Malt was distilled.

It is important to emphasise the proposals are now subject to wide-ranging consultation. In early March, we were greatly encouraged by the positive feedback received from SWA members at a special seminar attended by some 80 industry representatives from 17 companies. After further consultation with members, we will consult non-members, before taking matters forward with government.
These are far-reaching proposals, and while there may be debate over the term Blended Malt Scotch Whisky, SWA members believe that, when considered as a package, they offer the right blend for Scotch – working in the best interests of consumers and distillers.

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