I 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.)
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.
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.
Public Affairs Manager
Government & Consumer Affairs
Scotch Whisky Association
20 Atholl Crescent, Edinburgh, EH3 8HF, United Kingdom
t: (+44) 0131 222 9230
m: (+44) 07730 496 151
f: (+44) 0131 222 9237