Bottling outside of Scotland

Mel G. from Manila, Philippines asks:

Dear TSB,

Can a whisky distilled and blended in Scotland, but bottled in another country be called a blended Scotch whisky? There is a bit of an anomaly here in Philippines, a 5yo distilled in Scotland, but bottled here is labelled "blended Scotch whisky".

Your clarification is much appreciated.

-Mel

I had heard from an independent bottler that whisky must be bottled in Scotland, but my own reading of the law doesn't mention a requirement for place of bottling. A quick missive to the Scotch Whisky Association clarified all:

Kevin,
You are correct – there is currently no requirement for Scotch Whisky to be bottled in Scotland.  However, if bottled abroad, as in Scotland, nothing may be added other than water and spirit caramel to adjust colour.

One of our proposals for legislation is that in the future all Single Malt Scotch Whisky would have to be bottled in Scotland, but that would not affect the bottling of other categories of Scotch Whisky overseas.

With best regards,
Glen Barclay
Director of Legal Affairs
Scotch Whisky Association

Next week we'll hear from David Williamson of the SWA on the topic of "bottling of other categories of Scotch Whisky overseas".

Comments

[Johnny RnR]

I understand that the SWA has the job of ensuring that Scotland's whisky economy keeps rolling, but requirements on bottling inside of Scotland would hurt exports.

Unless I'm mistaken excise tax is leveled on bottles; shipping a container of cask strength whisky to a foreign country for later bottling at 80 proof would significantly lower the excise taxes paid when the spirit leaves the warehouse.

Am I right on this or totally off base?

[Vivek Baliga]

As long as use of water from scotland (which is one of the large drivers of the taste) is maintained, what problems can arise from overseas bottling other than usual quality control issues? Wouldn't this make the industry more dynamic and allow for a larger audience to experience SMS?

[Kevin Erskine]

Great questions guys.
I don't know all the answers, but here are my thoughts...

I BELIEVE excise tax is based on alcohol volume, so the "watered" part isn't taxed the same way, but I could be wrong on that.

But Bottling in the UK keeps jobs IN the UK, doesn't it?

Also, If you ship a cask, you have absolutely NO quality control - it could be adulterated with water taken from the Ganges river. I would dismiss that thought that casks of Scottish water are being shipped along with the casks of whisky.

I honestly wonder if French wines are allowed to be bottled in other countries.

Coca-cola is, but that is under supervision of the Coca-Cola company. I don't think individual distilleries could afford that sort of distribution scheme.

[Ed Patrick]

Premium Bottlers Inc., a new company in Ontario, Canada, has just launched a line of bottlings here. They import casks of Single Malt Scotch and bottle at 46% abv. The Canadian government requires that "Canadian content" must be added, so they marry the Scotch with 1% of Canadian Single Malt whisky. The Companions of The Quaich in Toronto tasted it for the first time last night (October 25) and can happily report that the flavour is indistinguishable from the distillery bottlings. They are not allowed to call it Scotch or single malt; it simply becomes a Vatted Malt Whisky. The Scottish distillery is identified on the bottle, but not the Canadian distillery.
Ain't life great?

[Fred Vincy]

To ask for further clarification based on Vivek's and Kevin's comment, must the water be from Scotland? Barclay's letter suggests no.

I would assume (am I wrong?) that distilled water should taste identical regardless of source, but clearly using anything other than distilled water from outside Scotland would be worrisome....

[Steve Levin]

Actually, Coke definitely tastes different in other parts of the world. UK/Ireland Coke is a nasty thing, in my opinion.