DISCUS, Single Malt Commission Support TTB Plan on Identity Standards
Both Distilled Spirits Council of the U.S. and American Single Malt Whiskey Commission "are in complete agreement" on the need for an American Single Malt Whiskey standard of identity, they said in a joint letter to the Alcohol & tobacco Tax & Trade Bureau. In particular, they agree the standards should required American Single Malt Whiskey:
- be distilled from 100% malted barley;
- allow producers to create brands in the category that are distilled from brands other than barley, provided those grains are clearly denoted on the label;
- incorporate a 700-liter live oak barrel limit;
- allow the sue of used, uncharred new and chared new oak barrels, and
- prohibit the use of harmless flavoring, coloring and blending materials.
In a separate comment, DISCUS called for American single malt whiskey to be mashed and distilled entirely at one U.S. distillery and must be mashed, distilled and aged in the U.S.
DISCUS also said it would support a 24-month use-up period of existing American Single Malt Whiskey labels that do not meet the eventual definition. "This should provide distillers enough runway to sell through their products and avoid undue financial burdens," DISCUS said.
DISCUS also said it was important for distillers to be allowed to use either used, uncharred new, or charred new oak barrels. It noted "the vast majority of international single malt whisky is granted this flexibility" and saiod "it is important for American distillers to also have this ability to make innovative barrel choices." But DISCUS also said the label should disclose the type of barrel used "to showcase the different varieties of barrels used as well as their impact on the flavor profiles of the whiskey."
Responding to a TTB question, DISCUS opposed the use of coloring, flavoring or blending materials in American Single Malt Whiskey, saying addition of such materials would undermine the reputation of the category as a natural product.
DISCUS said it doesn't support the term "Blended American Single Malt Whiskey" as it wouldn't reflect traditional single malt around the world and is contrary to the critical component of the definition requiring a single malt be distilled at a single distillery. However, DISCUS also said it wouldn't oppose the introduction of a "Blended American Malt Whisky" or "American Blended Malt Whisky."
Finally, DISCUS said addition of a standard of identity for American Single Malt Whisky would have a positive impact of competition in the U.S. bev/al market.
Separately, the American Single Malt Whisky Commission (ASMWC) said there are three "key points of differentiation between the Scotch Whisky regulations for single malt and TTB's proposed Standard of Identity for American Single Malt Whiskey that should be addressed: a minimum age, use of a pot still during distillation, and mashing and fermentation at the facility of distillation. As to age, ASMWC noted that unlike Scotland, which "is a small and very uniform climate from one end of the country to the other, America has a much broader and more varied regional climate reality that impacts whiskey-making in profound ways from region to region and even state to state. Imposing an arbitrary minimum age requirement for the entire country would not only be unprecendented and unfair, but also impractical."
ASMWC opposed a pot still requirement, calling such a requirement impractical and limiting and saying other measures can be implement to achieve the objective of insuring that more grain flavor in retained in the final distillate.
ASMWC also opposed a requirement that mashing and distilling occur at the same facility. It noted that while the UK regulations require mashing and distilling at the same facility, no such requirements exist in Europe or many other prominent single malt whiskey-making regions across the world. Also, it said. the single malt category has evolved over time in the U.S. with many distillers partnering with breweries and other facilities to produce their mash.