American Single Malt Whiskey

This official recognition of this new American Whiskey category came after years of lobbying by trade organisations and distillers such as Shanahan's, who started making their American single malt whiskey from 100% malted barley in 2004. (Image above Shanahan's ageing warehouse.)

American Single Malt Whiskey must be made from a:

1. fermented mash of 100% malted barley produced in the United States;
   
2. with a maximum distillation strength of 80% alc./vol. (160 proof), distilled at the same distillery in the United States;
   
3. matured in used, charred new, or uncharred new oak barrels, with a 700 litre maximum capacity stored only in the United States for a minimum of two years*;
   
4. with no neutral spirits may be added; and
   
5. no colouring, flavouring, or blending materials, except for caramel colouring, and this must be disclosed on the label.

The requirement that American Single Malt Whiskey be aged for a minimum of two years is scheduled to be published in the Federal Register on Wednesday 18th December, with an effective date of 19th January 2025.

Letter sent to the TTB by Distilled Spirits Council of the United States (DISCUS) and American Single Malt Whiskey Commission (ASMWC) on 29 July 2024

Mary Ryan Administrator Alcohol and Tobacco Tax and Trade Bureau
1310 G Street, N.W., Box 12
Washington, D.C. 20005

Re: Notice No. 213/Notice of Proposed Rulemaking: Proposed Addition of American Single Malt Whisky to the Standards of Identity for Distilled Spirits (87 Fed. Reg. 45727 (July 29, 2022))

Dear Administrator Ryan:

On behalf of the Distilled Spirits Council of the United States (DISCUS) and the American Single Malt Whiskey Commission (ASMWC), a national association representing more than 100 producers of American Single Malt Whiskey across the United States, we once again commend the Bureau for listening to industry calls and releasing the "Addition of American Single Malt Whisky to the Standards of Identity for Distilled Spirits" notice of proposed rulemaking. With today being the two-year anniversary of that notice, our Associations are writing to urge the Bureau to follow through with developing an official standard for this category, which stands as one of the fastest growing categories of American Whiskey over the past decade.

Adoption of new regulations and a formal standard of identity is of critical importance to our members, suppliers, trade partners and, most importantly, our consumers. To reaffirm our position regarding questions raised by TTB in the NPRM's, DISCUS and ASMWC are aligned that the eventual American Single Malt Whisky standard should: (1) be distilled from 100% malted barley; (2) allow for the ability for producers to create brands that are distilled from grains other than barley, provided that those grains are clearly denoted on the label (e.g., American Single Malt Rye Whisky); (3) incorporate a 700-liter oak barrel limit; (4) allow the use of used, uncharred new, and charred new oak barrels; and (5) prohibit the use of harmless flavoring, coloring, and blending materials.

In the two years since the Bureau issued its notice, the need for a formal standard has grown ever-more urgent. From the largest multinational spirits companies to smallest regional craft distilleries, a significant amount of investment has been poured into American Single Malt Whiskey. This highlights the desirability of the category but also brings into stark focus the risks posed by the lack of a standard.

We also note the mounting competitive pressures globally, as other emerging single malt nations such as Japan support their distilleries by adopting formal regulations more quickly than the U.S.

American Single Malt Whiskey is also facing threats from brands with questionable or outright misleading labeling, as well as spurious and self-motivated claims that American Single Malt broadly is of suspect quality. While members of the ASMWC take a voluntary oath to adhere to its standards, many other single malt producers are currently free to abuse the simple set of production requirements. The Bureau is well positioned to solve this problem by issuing formal regulations and a standard of identity.

In addition to producers, consumers will benefit from a clear definition of what constitutes American Single Malt Whiskey. This new standard will establish trust in the category, clarify label declarations, and equip consumers with the necessary information to make informed purchasing decisions. The formal establishment will also signal to the world that we recognize American Single Malt Whisky as a unique category, like Bourbon, that deserves to be defined, recognized and protected.

American Single Malt promises to be the next big thing in whiskey globally. There is widespread industry and consumer support for formalizing a standard of identity. As DISCUS and ASMWC continue to promote the protection of this category, both domestically and through free trade agreements around the world, an established definition is imperative for the development of greater recognition and protection. We look forward to working with the Bureau in this important matter. Please do not hesitate to contact us if we can be of any assistance through this process.

Sincerely,

Steve Hawley President American Single Malt Whiskey Commission

Chris Swonger President & CEO Distilled Spirits Council of the United States