Per TTB’s request for public commentary on their Notice of Proposed Rule Making for American Single Malt Whiskey (NRPM for ASMW) [4], this document represents the researched & reasoned views of the Whiskey Lodge community and its admins. 

Who are we?

We are an online community (primarily on Discord[1]) open to all whiskey drinkers and passionate spirits enthusiasts. Besides discussing and enjoying spirits together, we spend a fair amount of time discussing industry news and regulatory standards, and we think we have something to add to this conversation. We are also loosely associated with the https://www.reddit.com/r/AmericanSMW community, which shares an Admin.

Statement of Solidarity with the ASMWC

The Whiskey Lodge stands with the American Single Malt Whiskey Commission (ASMWC) and more than 100 distillers across America in supporting the creation of a new Standard of Identity for American Single Malt Whiskey (ASMW). Recognizing this category will serve to greatly benefit American distillers, the whiskey industry at large, and most importantly consumers. We fully align with the Commission’s Petition and Comments in response to NPRM No. 213 and urge TTB to ratify this new category as swiftly as possible.

Commentary on Proposed Rules

We have created a more detailed document for review (linked below) which will be submitted to the TTB which includes some detailed analysis of the provisions of the proposed language as well as a suggestion of updated proposed language. This document contains the substance of that document at a higher level.

The Whiskey Lodge's Public Comments in Response to TTB's NPRM for ASMW.pdf

Attached are some points for consideration and a wish list for what properties we would like the new rules to maintain or adjust.

We fully support that American Single Malt Whiskey should be encoded as the 6 rules proposed by the ASMWC [9], plus the deliberate relaxations of the pattern of American whiskey regulation that emerge from the proposed rules, as attached.

We think that "Allowable coloring, flavoring, blending materials permitted" should be restricted to just E150a to be consistent with Scotch Whisky and world Single Malts to ease consumer understanding domestically and abroad and to facilitate the export of such products to foreign markets.

We believe that there should be a definition of Straight American Single Malt Whiskey.

We believe that there should be a definition of a type of whiskey for products that are composed of American Single Malt Whiskey from more than one distillery, but assert that these products should not be called "Blended" for reasons we detail in the attached analysis.

We believe that "American" should be optional when a more specific State or region is specified.

In the attached letter we detail alternative language for the proposed rules to clarify our position on these points.

---

Thank you for your consideration of our comments on this matter. We look forward to seeing a definition of American Single Malt Whiskey that satisfies TTB, the producers of ASMW, particularly the ASMWC, and consumers of Single Malt Whisky worldwide.

Sincerely,

Douglas Christopher Ilijev, Admin of The Whiskey Lodge & /r/AmericanSMW

Phillip Davis Johnson, Admin of The Whiskey Lodge

Keehyuk Kim, Admin of /r/AmericanSMW

with:

The Whiskey Lodge Admins & Staff,

The Admins of /r/AmericanSMW,

And the petitioners at our change.org petition [10]

 

---

References

The Whiskey Lodge
[1] The Whiskey Lodge Discord: https://discord.gg/Y84jQeCbUM

[2] The Whiskey Lodge Twitter: https://twitter.com/TheWhiskeyLodge

/r/AmericanSMW
[3] The American Single Malt Whiskey community on Reddit: https://reddit.com/r/AmericanSMW

The Proposal Under Discussion
[4] TTB’s NPRM for ASMW https://www.federalregister.gov/documents/2022/07/29/2022-16244/proposed-addition-of-american-single-malt-whisky-to-the-standards-of-identity-for-distilled-spirits

The Standards of Identity
[5] Standards of Identity for Distilled Spirits: https://www.ecfr.gov/current/title-27/chapter-I/subchapter-A/part-5/subpart-I

[6] Standards of Identity > Alteration of Class and Type: https://www.ecfr.gov/current/title-27/chapter-I/subchapter-A/part-5/subpart-I/section-5.155

[7] Standards of Identity > Bottled in Bond: https://www.ecfr.gov/current/title-27/chapter-I/subchapter-A/part-5/subpart-F/section-5.88

The Scotch Whisky Regulations
[8] The Scotch Whisky Regulations (SWR) 2009: https://www.scotch-whisky.org.uk/media/1519/swr-guidance-for-bottlers-and-producers.pdf

The ASMWC
[9] The American Single Malt Whiskey Commission: https://americansinglemaltwhiskey.org

Our Petition
[10] (This document.)

Our Detailed Thoughts

[11] The Whiskey Lodge's Public Comments in Response to TTB's NPRM for ASMW.pdf

Further Writing (Research & Analysis)
[12] See also a more detailed write-up of research and reasoning for the suggested changes by Doug Ilijev (@DemiTastes) at https://medium.com/@demitastes/a-new-whiskey-category-explaining-american-single-malt-whiskey-8aafdeb2011e (Entitled: A new whiskey category: explaining American Single Malt Whiskey)