The Irish Whiskey Technical File (now officially referred to as the ‘Product Specification Sheet’) has long been lauded as an immovable force that, cannot and will not be changed, regardless of its historical inaccuracies nor its stifling of innovation.
As many of you will know, the current Irish Whiskey Technical File 2014 (approved in 2019) has long been a source of consternation for Irish whiskey professionals and enthusiasts alike, for a number of reasons but most notably for its definition of Single Pot Still Irish Whiskey.
Since its drafting in 2014, it has laid out the definition of what can be considered “Single Pot Still Irish Whiskey” as a minimum of 30% malted barley, 30% unmalted barley and up to 5% other grains. This last section relating to the “up to 5% other grains” is the main source of consternation, as it ignores almost 200 years of mixed mashbill history in Ireland, in lieu of reflecting the common practice of making by one company, who were lucky enough to be present when the draft was being penned. Despite this 5% rule being proven as woefully inaccurate, the rule has remained in place, despite the near total majority of the history of Irish whiskey mashbills from 1800-1966 not conforming to this 5% rule.
These mashbills aren’t just things of the past either, in-fact, there has been at least 1 “non-GI compliant Pot Still” (aka exceeds the 5% rule of other grains) has been bottled and released in every decade since the year 1900.
As such, it is not only shameful to see hundreds of years of Irish distilling history ignored but this current 5% rule also stifles any attempt at either historical accuracy or innovation with adjunct grains. A person who wished to simply recreate the fantastic tapestry of mashbills from the 1800’s would not be able to call any with over 5% other grains ‘Single Pot Still Irish Whiskey’. This is incredible, considering that these were the recipes that built the incredibly successful ‘golden age’ of Irish whiskey that all our industry marketeers are so eager to harp back to.
Worryingly, Irish whiskey mashbill history is often struck off as “Scotch Lite”, lauding tales of single malt production outstripping single pot still in Ireland, which is just not true. Single malt whiskey has never been the mainstay of Irish whiskey production, UK tax records show that before and after the implementation and repeal of the malt tax (1785 – 1855), single malt whiskey never made up more than 5% of total production in the country.
As such, it is our responsibility as an industry to correctly interpret our history and have that reflected in our Technical Files. There are flavours that have been perfected and experimented with that have all but been eradicated due to an erroneous definition and now we need to see that change.
One of my largest fears is that Irish whiskey producers continue to be shackled by this 5% rule and we begin to see foreign distilleries create historically accurate (over 5% other grains) ‘Single Pot Still’ recipes and gain traction ahead of us, around the world. The world of mixed mashbill distillation boasts amazing flavours that are not found in other categories and it is not hard to imagine American or Australian distillers becoming successful with Single Pot Still expressions that are more popular and more historically accurate than the Irish can produce.
The day that the first ‘non-GI’ compliant Single Pot Still American whiskey arrives on Irish shores will certainly give us pause to think.
A European GI is supposed to protect historical production methods, so in order for Irish distilleries to simply be allowed to continue our actual culinary traditions, the Irish Whiskey Technical File needs to be revised to reflect a definition that actually encompasses what ‘Single/Pure Pot Still Irish Whiskey’ was.
As we discussed on Potstilled Radio’s ‘Dissescting the Technical File’ epsiode in 2019 (link to listen here) the Technical File is actually far more flexible than the powers that be have led us to believe. According to EU law, Technical Files can be amended by “Any group having legitimate interest”, in-fact, according to EU legislation, changes can even be enacted locally, as they often are in other GI categories.
According to Article 31 of EU regulation 2019/787 “Standard Amendments”, which are changes that do not change the legal ‘spirit’, ‘geographic definition’ or change the name of a GI can be dealt with at country/member state level.
This is actually what was enacted in 2019, when the Technical File on Irish Whiskey was re-written and re-published four separate times with significant changes before reverting back to the current 2014 edition, all without EU ratification (03/05/19, 20/05/19, 05/07/19 & 17/7/19).
Thankfully, leaning on this exact regulation, the Irish Whiskey Association announced, at its last general members meeting of 2020, that it would be opening an “internal member consultation” in which they are welcoming proposed amendments to the current Irish Whiskey Technical File from its member companies. Interestingly, they cite that any changes need to reflect long standing industry practice and any proposed amendments need to be cited with supporting evidence as to why it can be changed.
Therefore, I feel that this is a perfect opportunity to re-state that the current Single Pot Still definition is not fit for purpose. It is in no way historically accurate nor does it encompass any of the fantastic flavour tapestries that existed in Irish whiskey pre-1966.
So what definition could reflect Ireland’s mixed mashbill history, accurately?
Thankfully, a massive amount of research into documenting and archiving Ireland’s historic mashbills has already been undertaken by historian Fionnán O’Connor. As a part of his PhD. Research into historic Irish whiskey mashbills he has uncovered mountains of tax, distillery and industrial archives, all detailing the mashbill history of Irish distilleries through the late 1700’s, throughout the 1800’s and the first half of the 1900’s. All of which outline the industry wide practice of mixed mashbill distillation, which saw a rich tapestry of preferred mashbills that contained large percentages of oats, wheat, and rye.
Speaking to Fionnán, he was kind enough to share his thoughts on what a historically accurate Single Pot Still Irish Whiskey definition would look like, encompassing all our amazing mixed mashbill history, but also allowing for modern experimentation within a historical framework.
Instead of a whole new definition, he proposes an amendment to the current definition that would retain the current 30% malted barley minimum, as well as the 30% unmalted barley minimum, but would see the 5% maximum other grains changed to “up to 30% oats, wheat, and/or rye”, which Fionnán notes are the only other traditional adjuncts advocated by the category’s original producers.
Fionnán’s 30/30/30 rule would provide a category definition that would encompass nearly all mashbill releases from between 1855 and 1968, while also allowing for the relatively high oaten & wheaten mashbills of the early 1800’s. This definition not only allows for historical accuracy, and mashbill innovation but it also solidifies the currently vague wording of what ‘other grains’ actually are. In Fionnán’s definition he has specifically stated that only Wheat, Oats and Rye, would be included in Single Pot Still Irish Whiskey. This, he states, “reflects historical practice and would allay fears that other cheap adjuncts would debase the premium name that Single Pot Still Irish whiskey is building for itself.“
I for one, truly believe that Fionnán’s definition would not only accurately reflect Ireland’s distilling past, but would also allow distillers to explore the immense flavour tapestry that were abundant in Ireland’s distilling past. The immense amount of flavours that have been lost with the white washing of Irish whiskey mashbill history is astronomical and this 30/30/30 definition would welcome them back into modern times with open arms.
Lest we not forget also, that just amending this rule doesn’t just mean that all distilleries in Ireland just start making wild and wonderful mashbills, that won’t happen overnight. What it will do though, is allow for historical accuracy and a repatriation of the lost flavours of Ireland in those distilleries that do seek to ‘innovate’ utilising different historical grains.
As such, I implore any members of the Irish Whiskey Association to submit your own proposals to the IWA, calling for the revision of the Pot Still definition to reflect the amazing tapestry of mashbill history in Ireland. While I truly believe that Fionnán’s immense research provides the most historically accurate definition, everyone is entitled to their own opinions and whether you believe that the 30/30/30 is best or your own alternative, I have provided cited historical sources below to help with your own research and/or historically citing any submissions to the IWA.
Alternatively, if you are an enthusiast, and not a member of the Irish Whiskey Association, then I implore you to text, tweet, call, and bother you favourite Irish distilleries (that are members of the Irish Whiskey Association) to make their own applications to change the Single Pot Still Irish Whiskey definition. We are standing at a crossroads in our industry’s history and now is the time to act.
What’s more, it is important to have a critical mass of voices calling for change, as the actual main members group of the Irish Whiskey Association will not be voting on these proposed changes, the sub ‘Technical Committee’ will be. While this is still made up of member companies, it is a small committee, and it will still need as many voices call for change as possible to enact said changes.
Regardless, of whether you believe that Fionnán’s 30/30/30 definition is best or another definition all together, applications must be submitted by IWA member companies, in writing, before the 10th of February 2021.
Please see references for historic mashbills and generational non-GI compliant bottlings:
1824 & 1838 – Samuel Moorewood, Surveys of Excise Report, stating that general ractice in distilling in Ireland included “roughly 25-43% portion of oats or wheat.”
1831 – Board of Excise Report, defining the most prevalent Irish Pot Still mashbill as “2/3 malt and raw barley and 1/3 oats”.
1892 – Nettleton Inland Revenue Surveys, stating general practice in distilling in Ireland included, “10-30% adjuncts, with grains broken down as: 30-50% Malt, 30-50% Barley, 20-30% Oats, 5-10% Wheat, 3-6% Rye”
1908 – “What is Whiskey Case” – First ever proposed legal definition of general mashbill procedures for Irish whiskey, submitted to UK government by J. Talbot Power & Andrew Jameson, stating that it is common practice in Irish whiskey is a mixture of malt and barley with between 1/5 and 1/3 oats, wheat and rye.
1953 – Irish Pot Still Distillers Association first submission to an Irish government of a mash specific definition of Irish Pot Still Whiskey. Members: John Jameson & Sons. Ltd., John Powers & Son. Ltd., B. Daly & Co. Ltd., J. Locke & Co. Ltd., & Cork Distilleries Co. Ltd. Quote January 1953 “Barley Supplies about 80%, oat 15% and wheat 5% of the distilleries’ cereal requirements, and half the barley (about 40%) is converted into malt.”
Bottlings Released 1900-1951 (1951 Act, First Legislation by the Republic of Ireland)
[Almost Universally Non-Compliant]
Bottlings Released 1951-1960 (Last decade of robust Irish Pure Pot Still industry)
Redbreast (Gilbey’s) – Non-Compliant
Green Spot 10 (Mitchell & Son): Non-Compliant
Jameson PPS: Non-Compliant
Powers PPS: Non-Compliant
B Daly’s: Non-Compliant
Bottlings Released 1960-1967 (IDL formation. Core brands switch to blends)
Redbreast 12 PPS: Non-Compliant
Jameson 12 PPS: Non-Compliant
Bottlings Released 1968-1975 (building of New Midleton. Early Monopoly era.)
Knappogue 1950 PPS: Non-Compliant
Bottlings Released 1975-1988 (Building of Cooley. Late monopoly era)
1980 – Locke’s 34 year old Pure Pot Still: Non-Compliant
1983 – Old Comber 30 Pure Pot Still: Non-Compliant
1987 – Knappogue 1951 Pure Pot Still: Non-Compliant
1987 – Averys of Bristol Jameson 37 old Irish pot still, Non-Compliant
Bottlings Released 1989-2005 (Monopoly Dissolution Era)
1991 – Caddenheads Authentic Collection: B. Daly PPS, Non-Compliant
1991 – Caddenheads Authentic Collection: John’s Lane PPS Non-Compliant
c. 2005 – Willier Napier PPS (bot. 1989, branded and released c. 2005) Non-Compliant
Bottlings Released 2006–2011 (Launch of Pernod-Ricard ‘single pot still’ portfolio. All releases during this stretch produced in IDL’s New Midleton facility)
2011 – Cooley/Kilbegggan spirit laid down publicly as pure pot still. Non-Compliant
Archives: More information can be found about specific mashbill practices in the Irish Pot Still Distillers Association Records (National Library), Locke’s Archives (National Library), Comber Archives (Public Records Office NI) and the B. Daly Archives (National Archives)