When is a Non Aged Statement whisky (NAS) not a Non Aged Statement whisky?

When is a NAS not a NAS?

Typical example of Vintage Single Malt

Before I publish my review of the Benromach Organic, I would like to talk about a subject connected with the issue of No Age Statement whiskies or NAS bottling.
I suppose this could be titled: When is a NAS not a NAS?
Before writing my review, I did a Google for other whisky reviewers as well as on YouTube, who have reviewed the Benromach Organic to see what others think of it and found that many of them describe this whisky as a NAS expression!
This brought me to the conclusion that there are many, including popular and seasoned reviewers it seems, who are unclear as to the definition of what constitutes a NAS. (Either that, or I am mistaken in my understanding?).
Using the definition of Whisky Magazine and Malt Whisky Year Book, a bottle of whisky is considered to have an "Age Statement" if the age of the whisky, that is, the amount of time the youngest whisky in the final vatting, has spent in Oak barrels since distillation before bottling, is stated on the bottle.
The simplest case is a single cask malt which was distilled on January 1st 2000 and that same cask lay maturing for 10 years until on the 2nd January 2010, the whisky inside was used to fill up 340 bottles. The label would state “10-Years-Old”.
So what about when multiple casks of different ages are used? Well, if you had a whisky that was bottled from three casks, one is 50-years old, one is to 25-Years and the last is 5-years. Even if the vast majority of whisky came from that 50-Year-Old cask, the official age statement of that whisky will be 5-Years-Old.
Oddly enough, there is a campaign going on now to reinstate some blended whiskies produced by an independent bottler which were banned under the current interpretation of UK and European law. What was their crime? They stated on his bottle that say, 75% came from a 50-Year-Old, 20% from a 25-Year-Old and 5% from a 5-Year-Old. This really useful information apparently offended some big whisky companies and they demanded that the SWA ban the whisky as according to their interpretation, you are ONLY allowed to state the age of the youngest whisky in the vatting and forbidden to mention the age of the others!
So all this means that a Non-Age Statement bottling is when they do NOT state the age of the youngest whisky used in the vatting! Therefore, if the bottle does not print on its label for instance “10-Years-Old”, “18-Years Old” etc then it is a NAS.
Clear? Well not quite!
What happens, as in the case of this Benromach, when a bottle label shows both the Distillation date and bottling date of the whisky contained within the bottle but no actual age statement?

Benromach could have simply put an age statement of “6 Years” or “7-Years-Old” on their Organic but chose instead to, (in my opinion), go even further and actually state the date of distillation of the spirit and then the date of bottling, leaving it up to the person to calculate 2010 to 2016 means it’s 6 years in the oak. Nowhere however, does it actually say “6-Years”!
This apparently, according to many out there, therebye turns the whisky into a NAS!
It seems that making a simple calculation of taking away the Bottling Year from Distillation Year to obtain the actual years in the cask is somehow not stating an age?!

It’s like classifying someone who, instead of giving money to a poor person, they buy them a full wardrobe of clothes, build them a house, get them a job and introduce them to their daughter…. – and that person is classified as NOT having given to charity because no actual exact sum of money ever passed hands!
From my understanding of the Scotch Whisky Association Regulations 2009, the Benromach Organic seems to fall under the category of a “Vintage Age Statement“- bottling and not a NAS.
See here for full document but I’ll point out what I think are the relevant points.
If you look under LABELLING REQUIREMENTS – Age Statement Checklist (page 77-78), Section C.
See the label marked Glen Evans Distilled 1990 and bottled 2009.
According to my understanding of the regulations, I would classify Benromach Organic under Vintage stated Age Statement according to Checklist Section C.

I wrote to Benromach a few weeks ago asking how they classify their own whisky. As yet I have received no reply.
I thought that this had cleared up the confusion but then I received an email from a Rabbi from a prominent Kashrut organisation completely disagreeing with me.
He said that he considers any expression where they give it a marketing product name, where at any time they could cease to state age, vintage or bottling years a NAS.
He wrote:

R’ Mordechai, FYI, the recent year was quite challenging for many distilleries due to various reasons. Marketing teams were working probably harder than ever, trying to overcome some serious obstacles. One of the solutions that were smart enough to become popular amongst many of the whisky companies, was to practically name the label, rather than stating its age. And for those who are still anxious to know when the youngest was distilled and when it was bottled, some may specify the years, but that may vary on future releases, while the label name should stay intact. That’s why it’s true to say that Benromach is NAS; They do not promise to always make it 6YO.

So, if I understand correctly, he is arguing that if they do not promise to always guarantee an age statement or Vintage then the whole expression must be categorised as NAS.
לא קשיא
To this I would respond "Lo Kashya" – “I find his argument difficult to understand”.
אי הכי
– Take for example:
The Glenlivet Nadurra expression included an age statement of 16-Years-Old for many years and then all of a sudden stopped printing the age. The new Nadurras became NAS. However, none would argue that the old Nadurras had somehow magically retroactively become NAS bottlings! That seems to be his argument.
Just because the current version has no age statement, that doesn't delete the age statement on prvious bottlings!

Even if the next bottling of the Benromach Organic expression will state “Distilled in 2010 and bottled in 2017” (that is, 7 years), then this is still a statement of age, even though it is a different age to the previous bottlings with the same brand name! Who says that the age statement has to be consistent throughout bottling edition? It just has to state the age or Vintage!

Indeed, the Glengyle Kilkerran “Work in Progress” has a distillation and bottling year stated on the label. Glengyle released a new bottling edition every year or two showing the progress of the same casks. So each edition, the bottling years increased accordingly. The “Work in Progress 6” was 10 years in the cask. The current “Work in Progress 7” is 12 years old. Both of them are Vintage age statement expressions.
Now, suppose that the next bottling edition of the Benromach "Organic" fails to state on the label its distillation and bottling date. This will only mean that THAT edition IS a NAS whisky.
Until someone from Benromach or the SWA tells me otherwise, I believe that I have understood this correctly.

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