Campaign For Transparency

Two years of the fight for greater transparency in Scotch whisky

Our 2016 Scotch Whisky Transparency campaign set out to effect a change in the regulations governing the ability of Scotch whisky producers to communicate complete information about the age of their products.  Below is the latest update on our progress.

 

Since the founding of our company in 2000, we had practised transparency by telling people the age of all the components in our blends, not just the youngest.  We did this until it was challenged in 2016 by an anonymous Scotch whisky company for breaking an old, outdated law.  With that, we began our Transparency Campaign.

While we have found a legal workaround that allows us to achieve our primary goal – getting complete, clear and unbiased information into the hands of people who are actively seeking it – we have not yet been able to convince the Scotch Whisky Association (SWA) and its members that the law should be changed.

We remain, however, a voice for common sense on this issue.

With the recent news (February 2018) that some members of the SWA would like the organisation to loosen its interpretations of some laws regarding Scotch whisky production practises, and with the reported potential of Brexit to create desire amongst the industry for strengthening UK laws protecting Scotch whisky, we are hopeful that our proposal for a change to the law on age statements may be heard.  However, this will take time—likely years, rather than months.  We are hopeful and optimistic, but we must remain patient.

For the time being, the legal advice we have received is clear: with the current law still in place, we should not actively disclose the ages of all the components used in our blends; we are only legally entitled to actively communicate the age of the youngest.  

However, we can provide further information when we are asked for it by interested parties.

We believe that a deeper understanding of what goes into the bottle leads to a greater appreciation and enjoyment of what's in your glass.  So, if you’re interested in this information, if you’d like to know the ages of all the components in our blend recipes, we invite you to get in touch with us and ask. 

Call the office, drop us an email, contact us on social media or speak to us at events.  The information is available; we’ll do all we can within the current regulations to share it with you.  All you need to do is ask.

We will continue to register support for the campaign through our online petition as the fight for greater transparency in the world of Scotch whisky continues.  It is now down to the industry’s major players, the SWA, and ultimately, the lawmakers.

As ever, we remain grateful for your support.

Compass Box Whisky Co.

 

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.

 

Proposed Amendments
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.

 

Definitions

Within the ‘Technical Amendments to Current Regulations’ described above,
the following definitions apply:

 
Complete

Complete

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.

Clear

Clear

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.

Unbiased

Unbiased

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.

Component

Component

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

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

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).

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