The results of a consultation document regarding verifying the geographical origin and production and aging processes for Scotch whisky will be published in the coming weeks. But, asks, Ian Buxton, is such a procedure necessary? And, what does the industry think?

Does the good name of Scotch whisky need further protection?

After all,

  • the industry has several hundred years of trading behind it
  • the Government trusts distillers to correctly measure, declare and pay their taxes
  • the Scotch Whisky Regulations are entrenched in law
  • Scotch whisky is protected as a product of ‘Geographical Indication’ (GI)
  • the Scotch Whisky Association diligently polices the world for imitations (and energetically prosecutes them)
  • the reputations of many great brands go to reassure customers worldwide
  • advertising campaigns such as Chivas Brothers' ‘The Age Matters’ help explain labelling claims on the bottle
  • all the major companies are spending heavily on education for both the trade and the consumer, and
  • an ever-growing army of writers and bloggers are helping to spread the word.

So what else could possibly be added?

According to HM Revenue & Customs (HMRC) the answer is verification. In order to maintain its valuable GI status (where the quality and authenticity of a GI product is intimately linked to its geographical origin), it must be verified as compliant with the requirements for that product. HMRC has been designated as the UK verification authority for Scotch whisky and now plans to protect the category by making sure that the “real thing” goes through the five specified production processes of fermentation, distillation, maturation, blending and bottling/labelling.

The verification process will involve HMRC visiting every distillery in Scotland and checking their processes, something that will be repeated every two years. And, naturally, the distillers will have to pay. It’s not as if they have the option: Producers who do not have their processes verified cannot legally produce and market their product as Scotch whisky.

This sounds to me a little like Big Brother. Especially as the consultation process closed some months ago, resulting in a scheme which now enjoys support from the Scotch Whisky Association, the Department for Environment, Food and Rural Affairs (Defra) and HM Treasury. It is anticipated that, by March 2015, HMRC will have completed initial visits and will make public a complete record of production facilities with approved production processes and, separately, a complete list of verified Scotch whisky brands. Any operator who does not register, or fails to secure assurance of their processes, will not be recorded on these lists and any products produced by them will not be listed as verified.

The 47-page consultation document is available here.  However, responses were required by 7 December 2012. Alarmingly, two companies contacted by just-drinks appeared unaware of the scheme – and were understandably reluctant to be quoted directly.

“I’ve never heard of that,” said one. “I’ll have to ask my colleagues.”   In a written response to our enquiries, a well-known Highland distiller - who insisted on anonymity - said: “I do not know what will be involved, but cannot see what requires to be done as everything is fully documented at present.”

So, while larger producers will, presumably, have little difficulty in dealing with the new requirements within their existing QA procedures, how about the impact on smaller companies and, in particular, the new wave of boutique distillers.

Stuart Nickerson, until recently MD at Glenglassaugh, is currently in advanced planning for a new craft operation The Shetland Distillery Co Ltd, which will produce just 30,000 litres of spirit annually from a former RAF airfield on Unst. Surprisingly, he welcomed the scheme.

“My feeling is that verification is necessary and is, in fact, overdue”, he told me.

“Most, if not all, operators are compliant with the existing regulations but it would be relatively easy to circumnavigate the system or take short-cuts and not be found out. There are a number of markets that already ask for verification documents and these are basically self signed by operators and stamped by HMRC and/or the local chamber of commerce; really not satisfactory.”

“This verification, as I understand it will increase traceability of product and ensure that each process complies with the appropriate section of the regulations, from production through to bottling and labelling.”

“I am as yet not sure of the cost,” continued Nickerson “and so this may be a bone of contention, but with the increasing number of distillers and other operators then it is, in my opinion, essential that we have a system such as this that will ensure the integrity of Scotch whisky.”

And, he concluded, “The product is so valuable, not only to the brand owners and operators, but to the country as a whole, that we cannot allow any question marks to arise as to its integrity.”

A ringing endorsement, then, from those aware of the scheme. But, if our small sample is any guide, more needs to be done to spread the word.