American Single Malt Whiskey

[Jay]

Is there any formal opposition to the standards of Identity the American Single Malt Whiskey Commission have outlined?

I disagree with "Made from 100% Malted Barley"

I feel it limits innovation

Just curious if there are others out there who don't agree with all of the standards outlined.

[Tom Lenerz]

I don't have a dog in this fight, but I'm not sure how adding single malt whiskey to the standards of identity, limits innovation, it just gives America the same classification that many other countries already have. People can do less than 100% malted barley, already as Malt Whiskey or Whiskey Distilled from Malt Mash.

Unless I'm missing something here.

[Foreshot]

13 hours ago, Jay said:

I disagree with "Made from 100% Malted Barley"

Being made from 100% Malted Barley is the point. It's so that when you label something as "Single Malt" it actually is that. It's so that the customer knows what they are getting and is able to more easily compare similar products. It doesn't limit innovation, it limits misleading labels. You can make any kind of spirit you want. 

[Silk City Distillers]

Excuse the mansplainin.

Just to be clear here,  the "Single" in "Single Malt' doesn't have anything do to with the Malt.   Single designates that the distillate was produced in a single distillery, and thus not a blend.

There is almost no direct equivalent of this designation in US law/regs.  You could argue that Bottled-In-Bond might actually be the closest designation, since it requires the distillate to be produced by a single distillery in a single season, but then BIB adds other requirements that are not similar to "Single Malt".

Thus, a Bottled-In-Bond Malt Whiskey would be the actual closest comparison to a Single Malt whiskey under the rules of the Scotch Whiskey Association, EU rules, etc etc.

[Silk City Distillers]

Ironically, they don't designate a minimum age?

[Foreshot]

http://www.americansinglemaltwhiskey.org/

STANDARD of IDENTITY
- MADE FROM 100% MALTED BARLEY
- DISTILLED ENTIRELY AT ONE DISTILLERY
- MASHED, DISTILLED AND MATURED IN THE UNITED STATES OF AMERICA
- MATURED IN OAK CASKS OF A CAPACITY NOT EXCEEDING 700 LITERS
- DISTILLED TO NO MORE THAN 160 (U.S.) PROOF (80% ALCOHOL BY VOLUME)
- BOTTLED AT 80 (U.S.) PROOF OR MORE (40% ALCOHOL BY VOLUME)

[Silk City Distillers]

Non-distiller producers would meet the requirements?

[indyspirits]

2 hours ago, Silk City Distillers said:

 Single designates that the distillate was produced in a single distillery,

Pedant mode on:

And from 100% malted barley in a pot still aged for three years. At one low point in my life I read through all of the regs. Enthralling. Bottom line, as you said, no equivalent in the US

 

[indyspirits]

1 hour ago, Foreshot said:

- DISTILLED ENTIRELY AT ONE DISTILLERY

That will have the crafties throwing a fit.

 

[Foreshot]

3 hours ago, Silk City Distillers said:

Non-distiller producers would meet the requirements?

Based on this I would assume yes, same as the Scots. So MGP and others would be able to produce and sell it. The buyer would be able to call it Single Malt as long as they don't blend it with any other products. If you "forget" to show the producing distillery on the label then no one would know. BiB Single Malt you wouldn't. But that also means we would need another Type for it. 

 

2 hours ago, indyspirits said:

Pedant mode on:

And from 100% malted barley in a pot still aged for three years. At one low point in my life I read through all of the regs. Enthralling. Bottom line, as you said, no equivalent in the US

 

I would like to see the pot still part added. To me the pot still piece is an aspect of the flavor of this type of whiskey. While you can produce it in other still types it may not retain the similar flavor profile. For customers that like Single Malt they want a similar flavor profile. It's the reason there are classes and types in spirits so that customers have a general idea of what a product tastes like before they buy it. Without some strength to the system you could buy Neutral (made from any source), throw in whiskey essence and call it whiskey (ala India). 

The age thing I am ambivalent about, as long as an age statement appears on it. I hate NAS products that use misleading labeling to portray an older age. 

[DenverDeviation]

Just taking a stab at what the OP was driving at- My guess is that his issue is not with the 100% component. That doesn't make sense to me given the other existing standards of identity Tom pointed out. My guess is that his beef is with the 'Malted Barley' part. A whiskey made from 100% Malted Oats or 100% Malted Quinoa, which by some definitions could be referred to simply as 'malt' would be examples.  This whiskey would obviously not fit the commission's criteria of American Single Malt, and perhaps this is what he is referencing as limiting innovation.  It would be even more limiting to the producer of this type of whiskey if the commission attempted to block the use of 'American Single Malt(ed) Quinoa' or similar language on the label.

 

 

[bluestar]

3 hours ago, indyspirits said:

Pedant mode on:

And from 100% malted barley in a pot still aged for three years. At one low point in my life I read through all of the regs. Enthralling. Bottom line, as you said, no equivalent in the US

 

While there is no equivalent officially, the TTB won't let you use the term unless you are distilling and bottling in a single distillery, since it will be considered misleading. On the other hand, they won't require using the minimum age of the EU.

[bluestar]

22 minutes ago, DenverDeviation said:

Just taking a stab at what the OP was driving at- My guess is that his issue is not with the 100% component. That doesn't make sense to me given the other existing standards of identity Tom pointed out. My guess is that his beef is with the 'Malted Barley' part. A whiskey made from 100% Malted Oats or 100% Malted Quinoa, which by some definitions could be referred to simply as 'malt' would be examples.  This whiskey would obviously not fit the commission's criteria of American Single Malt, and perhaps this is what he is referencing as limiting innovation.  It would be even more limiting to the producer of this type of whiskey if the commission attempted to block the use of 'American Single Malt(ed) Quinoa' or similar language on the label.

Per the CFR, "Malt" stand-alone means malted barley. Any other malt in a whiskey description or type must specific the grain. While the CFR does not call out the latter, that is the TTB's interpretation, probably by extension of "Malt Rye" or "Rye Malt" being an official type in the CFR distinct from "Malt" in the use of malted rye instead of barley.

[Jay]

My issue is that the suggested S.O.I. is heavily borrowed from SWA regs.  The majority of S.O.I.'s call 51% or 80% so why alter the US S.O.I. formula to be 100%.  Some of my current "ASMW" wouldn't qualify as I use some non malted barley ingredients to build flavor profile not to cut costs.

I'm not too studied in Scotch Single Malt Whiskies but why is malted Barley so romanticized?  Does every distillery still malt their own barley to add another part of the story and step in their process?  I know few in the US do just curious if the same still holds true for other distilleries.  

To be clear I love the distillate from Malted Barley just curious why it needs to be 100%?

[Foreshot]

18 minutes ago, Jay said:

To be clear I love the distillate from Malted Barley just curious why it needs to be 100%?

Because it's what it single malt means, 100% malt. Having it mean one thing to Scotland and another to the US would confuse consumers. The SOI's are about the consumer side of things.

 

25 minutes ago, Jay said:

why is malted Barley so romanticized?

Because the Scots were the first to really develop great whiskeys and it's how they make it. Same as French wine, Russian vodka. People want to mimic it to honor and/or make money off it.

[indyspirits]

3 hours ago, Foreshot said:

I hate NAS products that use misleading labeling to portray an older age. 

I'm a big single malt scotch fan and I think this is the single most annoying aspect of the spirits craze. I dont care if it ages 36 months, but I want to know it's aged 36 months. I simply can't figure out why it's not a rqeuirement in the scotch regs.

 

 

[Jay]

On August 8, 2018 at 4:28 PM, Foreshot said:

Because it's what it single malt means, 100% malt. Having it mean one thing to Scotland and another to the US would confuse consumers. The SOI's are about the consumer side of things.

 

Because the Scots were the first to really develop great whiskeys and it's how they make it. Same as French wine, Russian vodka. People want to mimic it to honor and/or make money off it.

I, as a distiller do not want to mimic Scotch.  This is the problem with the definition it's trying to bring ASMW into the category of Scotch instead of blazing it's own trail.  It just does't seem right to me.  

[Tom Lenerz]

Again, the standards are just starting what single malt already means. I would have an issue with a distiller making "Bourbon" but only using used oak barrels. Ya they are innovating, but the standards are there to protect the product definition. If you want to do something that isn't 100% malt, it isn't a single malt. You can already do that, there are already lots of options for labeling in America.

[JustAndy]

This probably sounds snarkier than I intend but if you don't want to mimic Scotch, you probably shouldn't hope to rely on a term like 'single malt' that they have defined and marketed for 50+ years. 

[Thatch]

The meaning of Single Malt Whiskey is it comes from a SINGLE distillery whereas many Scotch Whiskey are blends from many distilleries.  A Single Malt Whiskey is made of 100% malt made from barley, whereas many Scotch whiskey blends also have other grains (corn, unmalted barley, etc) whiskey blended in. 

There is far more Blended Whiskey than Single malt being produced in Scotland these days.  

[Roger]

On August 8, 2018 at 7:00 PM, indyspirits said:

I'm a big single malt scotch fan and I think this is the single most annoying aspect of the spirits craze. I dont care if it ages 36 months, but I want to know it's aged 36 months. I simply can't figure out why it's not a rqeuirement in the scotch regs.

 

 

Actually scotch can't be called scotch or sold as scotch until it is at least 3 years old. So the NAS under 3 years isn't applicable. 

This unlike US Whiskey wherein it can be brought to market and sold as "Whiskey" at any time under 4 years old, provided it has an age statement.

Of course the reality is the US "Craft Market" is flooded with under 4 year old whiskey being sold with NAS because the TTB is not enforcing complaints against blatant offenders.  

Note to self: if you have had your DSP for under 4 years, you should use the age statement on your Whiskey. If not because you are afraid of being caught and fined by the TTB, at least because otherwise you are acting like a Sleezebag. 

 

 

[indyspirits]

On 8/20/2018 at 9:19 PM, Roger said:

Actually scotch can't be called scotch or sold as scotch until it is at least 3 years old. So the NAS under 3 years isn't applicable. 

My point is, I dont like NAS offerings.

 

 

[bluestar]

On 8/20/2018 at 9:19 PM, Roger said:

This unlike US Whiskey wherein it can be brought to market and sold as "Whiskey" at any time under 4 years old, provided it has an age statement.

Of course the reality is the US "Craft Market" is flooded with under 4 year old whiskey being sold with NAS because the TTB is not enforcing complaints against blatant offenders.  

Note to self: if you have had your DSP for under 4 years, you should use the age statement on your Whiskey. If not because you are afraid of being caught and fined by the TTB, at least because otherwise you are acting like a Sleezebag. 

Hear, hear! I must run into at least two more craft distilleries a month that sell NAS whiskey that in a candid conversation with an owner, maker, or salesman, I learn is not 4+ years old. I am also starting to hear more of the "well, it is blended with 4+ yo whiskey" justification, as well. Sheesh!

[saaz]

On 8/20/2018 at 7:19 PM, Roger said:

Of course the reality is the US "Craft Market" is flooded with under 4 year old whiskey being sold with NAS because the TTB is not enforcing complaints against blatant offenders.  

Note to self: if you have had your DSP for under 4 years, you should use the age statement on your Whiskey. If not because you are afraid of being caught and fined by the TTB, at least because otherwise you are acting like a Sleezebag. 

 

 

@bluestar

You only have to use an age statement if you make claim of "aging" whiskey on your label. The TTB put on web conference this year on Whiskey and that was covered in the webinar. According to Sarah Johnson - Sr Labeling Specialist you only need an age statement if you make a claim of aging on the label. We have tired to use the word rest and then they wanted us to put an age statement on the label. It's not that we are trying to be sleezebag's. We vat 15 gallon barrels with 30's. Of course the 30's have much more age on them. The process is confusing to most consumers. Leaving it off the label is a better way to handle it. 

Here is a link to the Webinar. 

https://zoom.us/recording/play/6ZUjUjTlis0MVXoxqZ6vlE2y6nqaR2CLZhko4XN-1uaF3807DgXBeMF__GiVXbeD?continueMode=true

[Tom Lenerz]

13 hours ago, saaz said:

@bluestar

You only have to use an age statement if you make claim of "aging" whiskey on your label. The TTB put on web conference this year on Whiskey and that was covered in the webinar. According to Sarah Johnson - Sr Labeling Specialist you only need an age statement if you make a claim of aging on the label. We have tired to use the word rest and then they wanted us to put an age statement on the label. It's not that we are trying to be sleezebag's. We vat 15 gallon barrels with 30's. Of course the 30's have much more age on them. The process is confusing to most consumers. Leaving it off the label is a better way to handle it. 

Here is a link to the Webinar. 

https://zoom.us/recording/play/6ZUjUjTlis0MVXoxqZ6vlE2y6nqaR2CLZhko4XN-1uaF3807DgXBeMF__GiVXbeD?continueMode=true

I'm not saying she didn't say that, but the CFR is the law, and the CFR disagrees with that interpretation. I will stick with the CFR. Below is the relevant passage, emphasis is mine.

§5.40   Statements of age and percentage.

(a) Statements of age and percentage for whisky. In the case of straight whisky bottled in conformity with the bottled in bond labeling requirements and of domestic or foreign whisky, whether or not mixed or blended, all of which is 4 years old or more, statements of age and percentage are optional. As to all other whiskies there shall be stated the following:

(1) In the case of whisky, whether or not mixed or blended but containing no neutral spirits, the age of the youngest whisky. The age statement shall read substantially as follows: “___ years old.”