SWA responds to “Blended Malt” criticism
April 9th, 2008I received this on Monday. It’s the Scotch Whisky Association’s (SWA’s) response to the criticism that is going around regarding the proposed new definitions of whisky, including the controversial “Blended Malt”. It’s only fair to show both sides of this story. Now that we have SWA’s attention, feel free to comment. (Be sure to also read my “Blended Malt” posting and comments from last week.)
Dear John
We read with interest your recent blog on the draft Scotch Whisky Regulations and thought it might be of interest to your readers if we set out again why the term ‘Blended Malt Scotch Whisky’ has been proposed by the industry/UK Government. We should also not forget that a much wider package of proposals are being consulted on and I’ve highlighted some of the key provisions below.
Choice of the term ‘Blended Malt Scotch Whisky’
There was lengthy industry discussion around the choice of the term and, in the end, it was chosen because the industry working group/SWA members believe it is the only description that accurately describes what the product is, in a manner which is comprehensible to consumers worldwide, both to the enthusiast but also the millions who enjoy the product but may know little about the category.
Consumers understand that ‘blending means mixing’ and blending is generally understood as meaning ‘more than one’. A number of companies have of course already changed their labels to use the description ‘Blended Malt Scotch Whisky’ and, encouragingly, there is no evidence to indicate any consumer confusion or resistance to the description. Any legislation introduced in the UK must of course also comply with EU law and under European legislation any combination of malt whiskies is defined as a ‘blend’.
We accept entirely the point you make on education. The SWA has always said that, whatever terms are introduced, the industry will need to take the opportunity to grow awareness and understanding of all the categories. We will be doing just that in the coming months. The aim is to ensure that everyone receives clear, consistent, and accurate information about what they are buying. (There is clearly little confusion about the term amongst whisky enthusiasts because, although some may not like the term, they understand what it means.)
It is also important to note that some of those in the trade who have voiced objections have their own narrow interests to promote. One objector, for example, recently advised the SWA that he was against the new terminology because he was currently selling a ‘Malt Scotch Whisky”, which sometimes contains a Single Malt, ‘but sometimes contained a blend of malts’. In other words, he was using the same ‘Malt Scotch Whisky’ label for different products.
Alternative Terms
A broad range of alternative terms were considered, for example ‘Malt Scotch Whisky’ and ‘Vatted Malt Scotch Whisky’. The term ‘Malt Scotch Whisky’ was, however, rejected because it was felt that it does not distinguish a blend of malts from Single Malt Scotch Whisky, as Single Malt Scotch Whiskies are Malt Scotch Whiskies. The average consumer is unlikely to know whether a ‘Malt Scotch Whisky’ is a Single Malt or a blend of malts from different distilleries. At the same time, the term ‘Vatted Malt’ has almost solely been used within the trade and it is significant that hardly any labels at all have ever featured that description. Again, it was agreed the term would not be understood by the vast majority of consumers worldwide.
Blended Malts have, in the past, been sold under a variety of names, including ‘Pure Malt’. The industry supports the proposed ban on the use of that term. Firstly, we believe it has been used by some to disguise the fact that the products in question are Blended Malts’, but there has also been confusion caused by the fact that the term ‘Pure Malt’ has been used on both Blended Malts and Single Malts. This has also resulted in confusion as to whether Pure Malt and Single Malt were the same, and some consumers believe Pure Malt is a superior category to Single Malt as a result of the use of the word ‘Pure’.
Clarity for consumers as to what each category of Scotch Whisky is will allow the industry to promote each category better by explaining its merits. The SWA would not accept recent comments by some that the word ‘Blend’ is in someway derogatory.
Consultation on the proposals
There has been a wide and detailed consultation over the last four years. The proposals were initially drawn up by an industry working group – with a cross section of producers represented – in 2004. Each company involved has interests in each category and was able to bring a broad perspective to the debate. The proposals were then considered and endorsed unanimously by the SWA Council, and an industry seminar held for members at which the proposals were explained, and questions could be asked.
Subsequently, in June 2005, the SWA issued a detailed consultation pack to nearly 90 non-member companies and other organisations with an interest in the Scotch Whisky trade. The proposals were then submitted to Government. Since then, they have been tested and scrutinised by government in Edinburgh and London, with a three month public consultation launched by the UK Government in December 2007. There have therefore been repeated opportunities for stakeholders to make their views on the proposals known.
The proposals are aimed at trying to protect consumers and to promote and protect the interests of the industry as a whole, covering both large and small companies, and all types of Scotch Whisky whether blends or singles. Some recent statements suggesting otherwise are, frankly, disingenuous. It is not in anyone’s interests for consumers to be confused about what they are buying.
The wider package of proposals
Whilst there has been focus on ‘Blended Malt’, the category terms are a small part of a much wider and very important set of proposals. We should not lose sight of the fact that the legislation will introduce much needed improvements in the protection of Scotch Whisky and consumers. Other welcome provisions in the draft legislation include:
- an explicit statement that Scotch Whisky must be wholly matured in Scotland.
- protection for the five regional names traditionally associated with Scotch Whisky production - Highland, Lowland, Speyside, Islay and Campbeltown.
- provisions preventing the use of a distillery name as a brand name on any Scotch Whisky which has not been wholly distilled in the named distillery.
- rules to prevent the misleading labelling of a Single Malt to suggest it comes from a distillery other than the true one.
- ban on use of the term ‘Pure Malt’.
- a requirement that Single Malts are bottled only in Scotland to prevent adulterated product.
- clarity on the use of age statements, including requiring the date of bottling, or the actual age, to be stated in addition to the distillation date.
I hope this is helpful and, as always, please don’t hesitate to contact us if you have any questions.
Best regards
David
David Williamson
Public Affairs Manager
Government & Consumer Affairs
Scotch Whisky Association
20 Atholl Crescent, Edinburgh, EH3 8HF, United Kingdomt: (+44) 0131 222 9230
m: (+44) 07730 496 151
f: (+44) 0131 222 9237
w: www.scotch-whisky.org.uk
April 9th, 2008 at 8:36 am
Hi John,
After reading both this response and your response with regards to this issue, I’m of the opinion that “Blended Malt” or “Vatted Malt” are the best choices. I never did like the phrase “Pure Malt”. Although “Vatted Malt” is already recognized and associated with the blending of malts amongst enthusiasts, the fact that labels hardly mentioned this in the past is a mystery to me. Wouldn’t a requirement by distilleries to mention this on labels years ago have prevented this current dilemna?? Not to mention the number of years wasted on education. It just seems to me that this could have been nipped in the bud some time ago. Regardless of what term is used, education has to be a top priority. Like you and many others, I’ve bought whisky with a little booklet looped over the neck that either described that particular whisky, or may have covered their entire line of whiskies. Wouldn’t such a booklet also be a prime place to include a definition of the term(s) being used on the label?? Or possibly a definition on the label itself, depending upon which is more cost effective. This is just my opinion, and you know what that and a quarter will get you.
Slainte,
Tony Menechella
April 9th, 2008 at 8:48 am
I truly appreciate the SWA’s weighing in on this issue, as their perspective is critical to understanding the intent of this change. However, Mr. Williamson’s next-to-last bullet point made me refer to your recent posting on the Glen Breton court decision, and specifically to a comment posted by Rob Carpenter:
“Assuming this battle is lost, next time I expect that SWA will go after anyone outside of Scotland who calls their product “single malt whisky,” claiming that’s confusing as well (even though it’s simply a description of a process), regardless of the brand name being used - mark my words.”
It would seem that Mr. Carpenter’s posting is especially timely, since the SWA apparently does, indeed, want control over this particular term which is being used by other distilleries worldwide. Or am I misunderstanding their intent on this point?
April 9th, 2008 at 11:21 am
Tony, education is key here, and the more information the distillers can included on their front or back label (or around the neck), the better.
Sam, hopefully David will chime in and respond to your comment.
April 9th, 2008 at 5:00 pm
Hi John,
According to SWA around 90% of all Scotch Whisky produced is exported.The U.S. is a big slice of that pie.By contrast U.K. consumption has exhibited a long-term decline.I dont recall any extensive consulting with the American consumer,I wasnt asked, were you?Most of their three month consumer contact was probably in London and Edinburgh.The new regulations will start up this June.
Anyone interested in “after the fact” education can find interesting data such as: The Consultation Letter,List of Consultees,Consultation Document,Draft SI and Impact Assessment , at the following location: www.defra.gov.uk/corporate/consult/whisky-regs08/index.htm
No bottling or barrels outside of controlled areas in Scotland?I dont know if Park Ave and Binny’s ect. actually got their casks as casks.I’ll have to ask Eric Braun if he has any of that Highland Park that spent some time aging in the Alps left. Did independents like Jack Wieber have their selections bottled in the UK or at home.Michel Couvier?Its a sad thing.
Single Grain has to be from a patented still ,cant be done in a pot,which means a whisky distilled at a single distillery in a patented still from water and malted barley with no other cereals added would be called a Single Grain Scotch!The sections on “enforcement” sound like we might have some new “Reminiscences of the Gauger”.
Anyway after reading all that info I need a dram.Maybe that special 10 yr.Laphroaig 1996 Single Malt bottled exclusively for the Widder Bar in Zurich.But where was it bottled?
While I’m at it I’ll raise a dram to you.Thanks for the great Fest last friday.Heres to you,the distillers on both sides of the pond, their employees and all who support them!!
By the by 2 questions,Hows Andrew Symington doing he looked more than a little under the weather last week? Also I hope you had a chance to taste the sample of BenRiach Chateau d’ Yquem Sauterne? If not ask Brett about it.
Slainte!
Mike
April 9th, 2008 at 6:06 pm
Mike, thanks for your comments. All good points. David Williamson of SWA said he will be responding in the near term regarding the points raised. Let’s see what he has to say.
Thank you for your comments about WhiskyFest. We thought it went very well. And speaking of Amdrew Symington, I think I caught what he has. (I shook his hand, but then again I shook a lot of hands.) I didn’t have a chance to taste the d’Yquem Sauterne BenRiach that night, but I get samples of all BenRiachs that come into the U.S., I look forward to that.
Cheers–John
April 10th, 2008 at 7:45 am
I read the SWA response to the blended malt controversy on your blog.
Whether the prognosticators are correct, on either side, there is another perspective that the SWA is missing. Whiskey’s most loyal consumers, the guys who spend eons on the web promoting whisky for free, by and large do not like the term blended malt, but the SWA is essentially telling them their opinion does not matter and they can all go to hell.
The SWA has an opportunity here for a PR coup. They could say thousands protested, we listened, and then go ahead and replace the term blended malt with vatted malt, or malt whisky, or whatever.
They would do well to remember the damage Morrison Bowmore did to itself when it told the Malts-L folks to go to hell over a foul Bowmore Darkest. The result was the FWP response from connoisseurs world-wide, something from which Bowmore will likely never fully recover.
This time it’s the SWA that seems to care not a whit what the most dedicated consumers of whisky think. They can choose to leave us disgruntled, or they can give us a bit of a feeling of having had a say, with the result that we dedicate even more energy to promoting their members’ products.
As for the months of education they propose, they already know that confusions are hard to avoid. That is exactly the tack they took with the Glen Breton affair. And besides “education” could include telling consumers what a vatted malt is. They may get the top tier writers on board (eventually, most also hate the term), but it will be decades before the second and third tier, and the occasional bloggers stop saying blends are bad, singles are good (of course I don’t share this opinion and truly enjoy many blends, that’s not the point). The only difference is that the “bad” category, now will include a lot more bottlings. And what of Single Blends, like Ben Nevis?
In any case, I think the SWA has an opportunity to co-opt the whisky fraternity, but if they proceed as they have been, they also run a huge risk of disaffecting many of us.
Davin de Kergommeaux
Canada
April 10th, 2008 at 1:16 pm
I received a response from David Williamson of the SWA (I’m not sure why he didn’t just post it up here.) I posted it below. Your thoughts, everyone?
—————–
Dear John,
Many thanks for your email. Your reader can be reassured that the SWA has not at any point during the ‘Glen Breton’ proceedings suggested it has any objection to the production of a ’single malt whisky’ in Canada. Indeed, as you are aware, Single Malts are now produced in a number of countries and the SWA has never objected to that.
The ‘Glen Breton’ case involves an entirely different issue, namely concerns that the use of ‘Glen’ would lead consumers to believe the product was Scotch Whisky due to the use of the word on many Scotch Whiskies sold in Canada, and the fact that ‘Glen’ names haven’t been used on whiskies other than Scotch. I would mention in passing that we raised our concerns with the producer before they started to sell the product, warning that we believed confusion was likely. Unfortunately, they did not reply to our letters and went ahead with the name anyway. Our concerns turned out to be justified as we found evidence of ‘Glen Breton’ being listed and sold as Scotch Whisky in over 30 instances, including in Canadian liquor board outlets.
We have therefore welcomed the Canadian Federal Court’s ruling that there was confusion in the Canadian trade and that ‘the ultimate consumer who thought he or she was ordering a Scottish single malt would never know that something else was served.’
I hope this is helpful clarification.
Best regards
David
April 12th, 2008 at 2:59 am
Dear Mr. Williamson, I believe strongly:
1) that the term “single malt scotch whisky” should be reserved for whisky produced at a single distillery in Scotland, and for that matter, that for whiskies produced using different stills or peating or other differences of process at a given distillery should be required to carry the name of the main name of the distillery displayed prominently on the label. Go ahead and put it in parenthesis’s, please just include it somewhere. For clarification on this point, Brora and Clynelish count as different distilleries.
2) that mixtures of single malt whiskies from different distilleries should be termed “vatted malt scotch whisky” and should display the names and the percentages of the , the ages, and the origins of whiskies produced in Scotland somewhere on the label (go ahead and put it on the back where only the most interested consumers will bother to read it). We promise not to be confused into thinking that “vatted” means extra value added tax.
3) any mixture of single malt whisky (ies) and grain whisky (ies) should be termed “blended scotch whisky” and should display the names and the percentages of the , the ages, and the origins of whiskies produced in Scotland somewhere on the label (again, go ahead and put it on the back where only the most interested consumers will bother to read it). However, there is no need to recommend a daily recommended value (such as for sodium, soluble fiber, etc in our morning cereal), we will figure out our own daily recommended allowance based on the quality of a whisky versus its price.
There you have it, complete transparency with no ambiguity or risk of confusing or misleading consumers. Please feel free to adopt and implement these solutions. With all due respect for your efforts to promote and protect the Scotch whisky industry, the current course of the SWA is clearly wrong. Period. No one is advocating “pure malt” so please leave it out of the discussion. If the SWA runs into any difficulty with more complicated issues such as changing the name of a distillery to market a vatted malt or the like, please contact me and I will be happy to help out.
Ewan Trotter, SSWC
P.S. Please quit picking on those Canadians with the maple leaf on their label, you come off as shameful bullies. The next thing you know they will be sued by some maple syrup industry group because some ninnies bought their whisky and poured it on their pancakes. Your efforts would be better spent going after frauds in China filling fake bottles of Johnnie Walker Black or keeping caramel out of whisky.