The verification process required by distilleries and independent bottlers to produce GI compliant Irish Whiskey, from a producer’s perspective.
The latest verification process is still relatively new and is a positive step in ensuring protection and quality for Irish Whiskey. That’s not to say it’s perfect. Of course, there is the consumer viewpoint that covers areas such as transparency, technical files, and labelling, but that is for another day.
GI and the verification process
There is a Geographical Indication (GI) scheme in place for Irish Whiskey which means that in order to label or market whiskey as Irish Whiskey it must follow product specifications set out in the Technical File written by the Department of Agriculture, Food and the Marine (DAFM). The GI for Irish whiskey, which is in place from January 2016, is there to ensure that Irish whiskey comes from Ireland and gives it a specific quality and reputation.
Before a producer begins its operations, they must apply to their Revenue office who will verify that the premises where the products are to be manufactured or processed are in line with the requirements in the Technical File.
The verification process covers the following stages of production and may involve a number of premises, but brewing, fermentation and distillation must occur at the same premises. All five stages of production must take place in an appropriately Authorised Tax Warehouse. Revenue will visit your premises and check all production stages in each premises.
Production for Irish Whiskey involves the following stages:
- Brewing
- Fermentation
- Distillation
- Maturation
- Blending, bottling and labelling.
You can see the checks that Revenue officers carry out in the following checklists:
https://www.revenue.ie/en/companies-and-charities/documents/excise/whiskey-verification-checks.pdf
Revenue will check systems and records that ensure the Technical file is being adhered to. They will also check for traceability of products.
Revenue will, on request, issue a certificate that the processes carried out at the production facilities are verified.
In addition to GI requirements producers must ensure that they are compliant with excise regulations on the movement of duty suspended product.
If the product was sourced from another verified facility, this must be verified by Revenue. If verified, Revenue will accept that the product received for maturation or bottling is Irish Whiskey.
If the product is sourced for maturation or bottling from another Whiskey producing facility, that facility must be GI verified.
Revenue can then issue a certificate that the processes carried out at the production facilities are verified.
After the production stage has been verified, the Revenue Officer must advise the local EHO by email, and also the National Environmental Health Service (EHS) that the systems and processes at the premises have been verified.
The Food Safety Authority of Ireland (FSAI) is responsible for any enforcement action against non-compliant Irish Whiskey production. Any enforcement action will be carried out by the local Environmental Health Officer (EHO) of the Health Service Executive (HSE) under a service contract with the FSAI.
Early this year the Irish Whiskey Association surveyed its’ members on the verification systems and presented findings to the Department of Agriculture, Food and the Marine (DAFM). Their survey got response from the majority of operational distilleries and on the whole, the survey was positive but nonetheless did highlight areas what were challenging, problematic or needed improvement. Labelling stands out as one of the areas that needs addressing.
In relation to GI verification two common findings arose:
- The frequency of verification checks to be changed to a two or three year cycle
- Inconsistencies in technical knowledge amongst verification officers in different counties
Labelling
With regards to labelling things become more challenging with the majority of respondents, suggesting that the labelling system is not working well. The five primary reasons the respondents had a negative perception of the system are:
- Environmental Health Officer (EHO) misunderstanding of the guidelines set out in the “Labelling and Marketing of Irish Whiskey” produced by the FSAI in February 2019
- Inconsistency in application of the guidelines
- Lack of written protocol on guidelines
- Lack of clarity on timelines\delays
- Lack of clarity on which statutory body is responsible
The Association produced the detailed findings of their survey along with recommendations in a report to the DAFM in April 2020.
Some, but not all, of the recommendations are:
- Training for verification officers. This should take place annually and with industry participation
- Written standard operating procedures to be put in place in the case of a dispute under the verification system
- DAFM, Revenue and HMRC to engage with IWA to conduct an industry consultation around timeframes for verification checks
- Establish a national labelling approval system by a single EHO/HSE team
- Label approval requests to be responded to within two weeks
- Clarification of roles of various bodies
DAFM have received the findings and recommendations and are currently reviewing the report. A response is expected shortly.
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