SCOTCH WHISKY TRANSPARENCY
We were recently informed that the way we’ve been communicating information about the age of the components in our whiskies is illegal. By sharing the entire recipe – by offering complete transparency around the age of each component whisky – we have been breaking EU regulations governing the marketing and promotion of spirits
It turns out that Scotch whisky is one of the few products where it is prohibited by law to be fully open with consumers. This is an issue that affects every corner of the Scotch world (from Single Malt distillers to blenders) and limits the ability of the producer to share pertinent information with their customers.
We believe the current regulations should change. That Scotch whisky producers should have the freedom to offer their customers complete, unbiased and clear information on the age of every component used in their whiskies. That those customers have the right to know exactly what it is they’re drinking.
Please read through the information below and – if you agree with what you see – take a moment to sign our Statement of Beliefs. Your support will help lobby UK and EU authorities to change the current regulations for the better.
Whiskymaker JOHN GLASER
Our Statement of Beliefs
We believe that Scotch producers should be given the freedom but not the obligation to include the age of all the components that go into their whiskies to bring them into line with the vast majority of other industries where total transparency is not only permitted but encouraged. We believe such a change would be positive in two ways:
1. It would give the consumer greater clarity about what has gone into the whiskies they’re buying – allowing them to make more informed choices.
2. It would benefit the Scotch industry itself by taking a positive step to satisfy the growing consumer demand for transparency, opening up more opportunities for creative blending across different aged components, and protecting Scotch’s current reputation for quality.
If you agree, please sign our Statement of Beliefs using the box below. Your support will help us lobby EU and UK regulators to change the current regulations.
to Current Regulations
The specific changes we propose be made to the current EU Regulations are outlined below. The substantial shift involves creating a third option for spirits producers with regard to how they communicate the age of their products.
It is currently against EU regulations for a producer to mention an age when talking about a bottle of aged spirit – whether on the packaging or in the marketing of that product – unless there is only one age mentioned and that age is of the youngest spirit in the bottle. This presents just two options for Scotch whisky producers in communicating the age of their products:
1. Age Statement
Age of youngest spirit only displayed on packaging and marketing materials.
2. No Age Statement
No information regarding age anywhere on pack or in marketing materials.
We propose the EU regulations should be amended in such a way that a third option be opened up for producers who want to provide full disclosure on the age of every component whisky that has gone into their product:
3. Full Disclosure
An amendment to the current regulations that would allow producers the freedom but not the obligation to provide complete, unbiased and clear information on every component whisky in their product – with or without a headline age statement outlining the age of the youngest spirit.
Within the ‘Technical Amendments to Current Regulations’ described above,
the following definitions apply:
By ‘Complete’ we mean a full listing of the ages of every component whisky that has gone into a given product, alongside a percentage figure given to one decimal place denoting the contribution of each component whisky to the finished products.
By ‘Clear’ we mean that when applied to packaging the information should be displayed with the same prominence as all other mandatory legal information (such as ABV, liquid volume etc.). When applied in off-pack marketing materials there must be no attempt made to obscure any element of the information.
By ‘Unbiased’ we mean that there can be no display bias towards the older component whiskies mentioned on-pack or in marketing materials – all component whiskies must be given equal prominence and equal type size. Moreover, the order in which the component whiskies are displayed should be determined by their proportionate contribution to the overall alcohol in the blend – with the component whisky that contributed the greatest alcohol displayed first and that which contributed the least displayed last. Where two parcels have contributed the same proportion to the finished whisky, the younger of the two should be listed first.
By ‘Component whisky’ we mean a parcel of whisky that can be distinguished from the other component whiskies in the final blend – at a minimum by its age but if the producer chooses to do so also by referencing other distinguishing features and terminology permitted under the current regulations (such as whisky type and category, distillery source, cask type, region information).
Freedom but not an Obligation
By ‘Freedom but not an obligation’ we mean that no producer should ever be compelled to provide Full Disclosure (in the same way that no producer is currently compelled to include Age Statement information within the current regulations).
Headline Age Statement
By ‘Headline Age Statement’ we mean ‘age statement’ as defined within the current regulations. That is to say that choosing ‘Full Disclosure’ does not preclude the inclusion of a prominent age statement, so long as this outlines only the youngest spirit in the bottling. (For example, a Single Malt whisky of 50% 30-year old whisky and 50% 40-year old whisky could [in line with current SWA regulation], be described as a 30-year old whisky and the producer could also choose to provide full details of the product's composition on the packaging and through the marketing of the release. However, they could not describe the product as a ‘40 year-old’ whisky or as a ‘35 year-old’ whisky).