The SWA Responds

I've stated before that I am a big supporter of the work that the SWA does to protect Scotch Whisky in the world market. But that doesn't mean we always have to agree!

As always, we are delighted to give the SWA a chance to respond to the past few posts which deride their proposal...

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Dear Kevin

We've read with interest your recent postings in relation to the draft Scotch Whisky Regulations.

Whilst we will have to agree to disagree on the merits of the term 'Blended Malt Scotch Whisky', I thought it might be helpful to set out for you and your readers why the term has been proposed by the industry/UK Government, and also to highlight the wider package of proposals that are currently being considered. 

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.   We should also remember that any legislation introduced in the UK must also comply with EU law and under European legislation any combination of malt whiskies is defined as a 'blend'.

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 internationally 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.

Alternative Terms

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 SWA 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. 

Certain comments by Bruichladdich have been based on a highly selective reading of the proposals (i.e. omitting two very relevant clauses).  Healthy debate is to be expected in an industry like ours - however, some of the comments made by the company have had nothing to do with informed discussion.  Indeed, the company in question has felt comfortable enough with the term 'Blended Malt' in the past to use it on one of its own products.

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.

Best regards

David

David Williamson
Public Affairs Manager
Government & Consumer Affairs
Scotch Whisky Association

Comments

[daavid]

the nice thing in any decision is that it can easily be 'post-rationalized' pro and contra. there are as many arguments beside 'Blended Malt Scotch Whisky'as against. the only aspect I always try to mention is that '... the millions who enjoy the product but may know little about the category ...' might not speak English on an advanced level (sometimes not even on beginner level) and they might not very well educated about whiskies. Therefore, Blended Malt Scotch might mean for them a mixture of a Single Malt Scotch and a Blended Scotch. it is just pure logic. I experience this sort of confusion very often. (It is also difficult to explain that Single Malt Scotch is not only Single, because it is made of malt only ... but it is also Single, because it is made in one Single distillery ... So what about a categorization i.e. Single Distillery Scotch Whisky, Malt Scotch Whisky, Blended Scotch Whisky)

[Steve]

I have a problem with this line:

"The SWA would not accept recent comments by some that the word “Blend” is in someway derogatory."

I find that point disappointingly unexplained in this rebuttal. If they worry that "Pure Malt" might be seen as superior to "Single Malt" by consumers, they are admitting that purity is a concept that has a connotation of value. And so a label of "blended", which is also a measure of purity, must therefore be seen as inferior to a "Single Malt" label. I'm not saying it's inferior, I'm saying it sounds inferior.

Maybe a more descriptive phrase is needed.

"... a single malt whisky"
"... a blend of single malt whiskies"
"... a blend of single malt and grain whiskies"

[Ronald]

Good day Ladies and Gentlemen,

In my opinion we have say good bay to vatted malt and pure malt, now we going to say hello blended malt.
We most make it so ease as possible, only single malt and blended whisky.
With compliments.

Ronald

[TF]

Hi Kevin,

"The SWA would not accept recent comments by some that the word “Blend” is in someway derogatory."

I have a problem with this too. My problem is that it perfectly expresses the SWA's position: putting its fingers in its ears and running away.

It is the SWA that is being disingenuous. My feeling is that they have made a serious error of judgement about the scale of the reaction to this term and that they may end up having to perform a humiliating climbdown as Diageo had to do after the Cardhu farce.

They will have been expecting a backlash and have decided to ride it out. It will be interesting to see how loud the noise gets before the legislation is passed.

Cheers,

TF

[Mark]

daavid's post gets it right:

"'Maybe a more descriptive phrase is needed.

"... a single malt whisky"
"... a blend of single malt whiskies"
"... a blend of single malt and grain whiskies'"

Rather than pushing a marketing phrase, tell the consumer exactly what he/she is getting from the company so they can decide what they want. For example, even though I know there are good blends out there, I tend to shun them in favor of single malts. I just tend to enjoy them more overall. The top-end cigar and pipe tobacco producers, makers of another traditionally crafted product, tell you what you get in their tobacco blends. This gives you a general idea of what to expect and the market decides what is good. Why shouldn't whiskey producers do the same?