Revenue Verification of Irish Whiskey

Introduction

Irish Whiskey is a protected European Geographical Indication (GI) under Regulation (EC) No 110/2008External link. Producers who produce and market their whiskey product under the Irish Whiskey GI must, after the 29 January 2016, ensure that the production processes used for the product are verified by Revenue as meeting the requirements of the Technical File for Irish Whiskey.  

This notice provides information on Revenue’s verification scheme for Irish Whiskey and should be read by any trader involved in the production and marketing of Irish Whiskey.  

Background

A Geographical Indication (GI) identifies a spirit drink which originates in the territory of a country or region and which has a given quality, reputation or other characteristic that is attributable essentially to its geographical origin.  Spirits placed on the market under a spirit drink GI must be verified as complying with the relevant technical file. 

There are three Irish spirit drink GIs provided for under the EU regulation – Irish Whiskey/Uisce Beatha Eireannach/Irish Whisky (Irish Whiskey), Irish Cream and Irish Poteen/Irish Poitín(Irish Poteen)[1].  To attain GI status, a spirit drink must be produced in accordance with the technical specifications for the GI in question. The specifications for the Irish spirit drink GIs are set down in technical files prepared by the Department of Agriculture Food and the Marine (DAFM) in Ireland and registered with the European Commission, as submitted by DAFM. The Irish Whiskey Technical File was submitted on 30 October 2014 and a copy is available at the DAFM website address below.  As the competent authority for the Irish spirit drink GIs, DAFM is responsible for providing advice and guidance on any matter relating to the interpretation of the relevant technical file.

[1] A separate notice will be available for Revenue’s verification of Irish Poteen.

Further information is available on the DAFM websiteExternal link

Revenue is responsible for the GI verification of Irish Whiskey and Irish Poteen in Ireland. DAFM is responsible for the GI verification of Irish Cream.

The Food Safety Authority of Ireland (FSAI) is responsible for action against non-compliant spirit drinks and such action will be taken by the Health Service Executive (HSE) under Service Contract with the FSAI.   Further information is available at https://www.fsai.ie - Spirit Drinks External link

In the case of a spirit drink produced in Northern Ireland, verification of the product is carried out by Her Majesty's Revenue and Customs (HMRC).

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Verification of Irish Whiskey

Revenue verification of Irish whiskey is intended to provide assurance that the production process meets the standards and specifications in the Technical File for Irish Whiskey. Revenue obtains assurance that a product satisfies the requirements for the Irish Whiskey GI by checking the systems and procedures used at the relevant production facility for each production stage.  The scheme of Revenue verification for Irish Whiskey is set out in pdfWhiskey Verification Checks (PDF, 348KB).

The following stages of whiskey production have been identified under the Technical File for Irish Whiskey and each stage must be verified.

  • Brewing*
  • Fermentation*
  • Distillation*
  • Maturation
  • Blending, Bottling & Labelling.

*Brewing, fermentation and distillation must be carried out at the same premises.

It is the responsibility of traders engaged in any of the above stages of Irish Whiskey production to show Revenue that the processes and systems used comply with the Technical File for Irish Whiskey if they plan to market the product as Irish Whiskey after 29 January 2016.

A person shall not market a product under the Irish Whiskey GI unless the product in question has been produced in a facility verified by Revenue, including a facility specialising in bottling and labelling spirit products.  

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Application Process 

Applications to Revenue for Verification

Traders who produce whiskey to be marketed as Irish Whiskey must apply to Revenue for verification.  A product cannot be labelled or marketed as Irish Whiskey unless the processes and systems used at all stages in its production are verified.

An application must be made in respect of each individual production facility where any of the following production stages are carried out:

  • Brewing*
  • Fermentation*
  • Distillation*
  • Maturation
  • Blending, Bottling & Labelling.

*Brewing, Fermentation and Distillation must be carried out at the same location. 

The Application Process

All applicants must complete and submit an pdfapplication form (PDF, 162KB) for verification to Revenue. Applicants should also submit a full description of the production process and materials to be used in the production of Irish whiskey, together with a description of the records and control procedures to be used to ensure adherence to the requirements for the Irish Whiskey GI.

Completed applications should be submitted to your local Revenue office.  A list of local Revenue offices is available at the following link: Revenue office locator

Applications for Existing Verified Premises

Production facilities that were verified by Revenue before January 29 2017 must reapply for verification by completing and submitting an application form to their local Revenue Office by 28th February 2017. The appropriate fee for each production stage to be verified must be paid (see Verification Fee below).

An Irish Whiskey production facility which is already verified by 29 January 2017 will be treated as verified until 29 January 2018 provided that;

  • Revenue has received a properly completed application for verification for each such production facility by 28 February 2017
  • The appropriate fee for each production stage requiring verification has been paid (see Verification Fees below)

Applications for New Production

Production facilities in Ireland which begin to produce Irish Whiskey on or after 29 January 2016 must be verified by Revenue prior to commencing such production. Applicants must complete and submit an pdfapplication form (PDF, 162KB) to their local Revenue Office.

Verification of new facilities will include an inspection visit by Revenue officials to the production plant prior to the commencement of production.  Producers who are bringing new production facilities into operation should apply to Revenue as early as possible and well in advance of commencing operations.

 

Applications for Blending, Bottling and Labelling in Ireland

Applications for verification of bottling and labelling in Ireland should include representative samples of labels in hard copy and/or in electronic form.  Copies of these labels will be forwarded to the FSAI by Revenue.  Where new labels are introduced between verification visits, copies should be retained for inspection by Revenue officers at the next verification visit. 

Traders who blend, bottle, or label Irish Whiskey outside Ireland should contact the Department of Agriculture, Food and the MarineExternal link on arrangements for the verification of these products. 

Brand owners, whose brands are blended and/or bottled and labelled on their behalf at another facility, need not apply for verification.  The blender/bottler of the whiskey is responsible for ensuring adherence to the GI standard and should apply to Revenue to have their facility in Ireland verified. 

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Revenue Verification

Records and Systems

Producers must be able to demonstrate compliance with the Technical File for Irish Whiskey.   Production processes, systems and procedures must be designed to ensure adherence to the technical specifications and requirements for Irish Whiskey. The relevant supporting data systems and records at each production stage must be adequate to satisfy Revenue verification checks in order to provide assurance of adherence to the GI standard and they must be readily accessible to Revenue officers for the purpose of verification. In addition, the systems and records must enable traceability of the products produced at the facility.

Compliance with the Technical File must be verifiable by Revenue throughout all stages of production, including where a product is moved for maturation or bottling to another facility (brewing, fermentation and distillation stages must be carried out at the same location). Traders who transfer Irish Whiskey for the final stages of production at another facility, must ensure the relevant systems and records provide full product traceability in all such cases.

Records must be retained for a period of 7 years.

Verification Visit 

In order to confirm that the production processes are compliant with the requirements of the Technical File for Irish Whiskey, Revenue will visit the facility and carry out a series of verification checks at each production stage.  The checks that will be carried out are set out in pdfWhiskey Verification Checks (PDF, 348KB).

Revenue will notify the trader in advance of the verification visit.

When Revenue is satisfied that the production processes comply with the requirements of the Technical File for Irish Whiskey the trader may continue to produce and market the product as Irish Whiskey, or to commence such production, as the case may be. 

Verification visits will be carried out annually at the outset.

Evidence of Verification

Revenue will, on request, issue a certificate that the processes carried out at the production facilities are verified. If the whiskey is moved from one verified facility to another verified facility in Ireland for maturation or bottling, Revenue will accept that the product received for maturation or bottling is Irish Whiskey, provided Revenue can verify from the documentation available for inspection that the product was sourced from a facility verified for Irish Whiskey GI purposes.

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Withdrawal of Verification

Revenue may refuse or withdraw verification where a person fails to pay the relevant verification fee, where the person does not produce, bottle or distil in compliance with the specifications for the Irish Whiskey GI, or otherwise fails to satisfy the checks carried out by Revenue in accordance with the scheme of checks at pdfWhiskey Verification Checks (PDF, 348KB).  Where verification is refused or withdrawn, Revenue will notify the person and give the reasons for the decision.  The person will have 14 days from the date of notification to make representations to Revenue in relation to the decision.   Revenue will consider the representations and then confirm or modify the original decision. 

Where verification has been refused or withdrawn, producers will be required to remedy the problem concerned and re-apply for verification to Revenue. Their application will be successful if the producer concerned can demonstrate that their production processes and systems satisfy the GI requirements and can be verified accordingly.

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Non – Compliance and Enforcement

The Food Safety Authority of Ireland (FSAI) holds responsibility for taking necessary follow up action (enforcement or otherwise) with applicants who fail to meet the standards for verification.

If Revenue is not satisfied that the production processes comply with the requirements of the Technical File for Irish Whiskey or the applicant otherwise fails to meet the requirements of the scheme, Revenue will advise the FSAI or its official agency, the Health Service Executive (HSE) of the non-compliance.

When notified by Revenue, the FSAI or HSE will determine what appropriate enforcement action is be taken. Appropriate enforcement action will be determined by the specific circumstances for the non compliance.

Verification Fees

Regulation (EC) No 110/2008 provides that the costs of the compliance checks are borne by the producer. Accordingly, the following fees apply for Revenue verification of compliance with the Irish Whiskey Technical File at each production stage.

Revenue Verification Fees
Process Fee
Brewing €250
Fermentation €250
Distillation €250
Maturation €250
Blending, Bottling & Labelling €250

For example, a facility where brewing, fermentation and distillation takes place will pay a total of €750 for verification, while a facility engaged solely in the final bottling stage will pay €250.  If all production stages take place at the facility and are to be verified, the total verification fee at that facility will be €1,250.

Where a trader blends at one facility and bottles another facility, a separate application must be made in respect of each facility and separate fee applies to each premises.

Traders will be advised by Revenue when and how payment should be made.

Certificates of Age

Revenue will continue to issue certificates of age for Irish Whiskey being exported to third countries.

January 2017

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