3. Compositional Aspects

Whisky
EU

This section provides the compositional requirements for the food category and/or food products in scope and information on permitted nutrients, ingredients, and additives.

3.1 Composition Requirements

General Food

Regulation (EC) 1334/2008 [1], Regulation (EC) 1333/2008 [2], and Regulation (EU) 231/2012 [3] fully apply in terms of composition. Other composition requirements as provided by the applicable EU law.

Category

Alcoholic beverages

Regulation (EC) 1334/2008 [1], Regulation (EU) 1333/2008 [2], and Regulation (EC) 231/2012 [3] fully apply in terms of composition. In addition, specific provisions set by Regulation (EU) 2019/787 [4] are also applicable, depending on the target spirit drink.

Product

Whisky [4]

• Only water and plain caramel (for coloring) may be added to the final distillate.
• Whiskey shall not be sweetened, even for rounding off the taste, or flavored, or contain any additives other than plain caramel (E 150a) used for adjusting the color. So the only permitted additive is E150a and it can be used quantum satis. E150a must meet the specifications set by Regulation (UE) 231/2012*.
• The minimum alcoholic strength by volume of whisky or whiskey shall be 40%.
• The addition of alcohol is not permitted.

The production process should follow the requirements as provided by Annex I.2 Regulation (EU) 2019/787** (a) (see Section 2.2).

[*] Reg. (EU) 231/2012 of 9 March 2012 laying down specifications for food additives listed in Annexes II and III to Regulation (EC) No 1333/2008 of the European Parliament and of the Council.

[**] Reg. (EU) 2019/787 of the European Parliament and of the Council of 17 April 2019 on the definition, description, presentation, and labeling of spirit drinks, the use of the names of spirit drinks in the presentation and labeling of other foodstuffs, the protection of geographical indications for spirit drinks, the use of ethyl alcohol and distillates of agricultural origin in alcoholic beverages, and repealing Regulation (EC) No 110/2008.

There is no definition at the EU level of tolerance limit for alcohol by volume and order of specific gravity. However, specific requirements may exist as national measures at the Member State level.

3.2 Raw Material Requirements

General Food

Some ingredients are covered by individual product standards, when used as raw material, they need to be compliant with individual product standards.

Category

Alcoholic beverages

Same as "General Food" above.

Product

Whisky

The starting raw materials for the production of whiskey must be malted cereals, with or without whole grains of unmalted cereals, which have been saccharified by the diastase of the malt contained therein, with or without other natural enzymes and fermented by the action of yeast [4]. 

3.3 Fortification

General Food

Fortification can be made following the rules of Regulation (EC) 1925/2006 [6] unless not authorized in the particular food standard.

Category

Alcoholic beverages 

Fortification is not permitted (Article 4 Regulation (EC) 1925/2006 [6]). 

Product

Whisky

Same as "Category" above. 

3.4 Other Permitted Ingredients

General Food

Composition requirements as provided by the applicable EU law.

Category

Alcoholic beverages 

Specific provisions set by Regulation (EU) 2019/787 [4] are also applicable, depending on the target spirit drink.

Product

Whisky

Water in the final distillation.

3.5 Permitted Additives

General Food

As established by Regulation (EC) 1333/2008 [2]. 

Category

Alcoholic beverages 

As established by Regulation (EC) 1333/2008 [2]. 

Product

Whisky

Plain caramel (E150a) quantum satis [2]. 

3.6 Permitted Flavors and Colors 

General Food

As established by Regulation (EC) 1333/2008 [2] and Regulation (EC) 1334/2008 [1].

Category

Alcoholic beverages 

As established by Regulation (EC) 1333/2008 [2] and Regulation (EC) 1334/2008 [1].

Product

Whisky

Plain caramel (E150a) quantum satis [2]. Flavoring is not permitted. [4] 

3.7 Permitted Processing Aids 

General Food

As established by Regulation (EC) 1333/2008 [2].

Category

Alcoholic beverages 

As established by Regulation (EC) 1333/2008 [2] and Regulation (EU) 2019/787 [4].

Product

Whisky

There are no specific requirements related to permitted uses of processing aids and the production process should follow the requirements set by the law (see Section 2.2). The use of processing aids in the production process is clearly regulated by Regulation (EU) 2019/787 [4] for other spirit drinks such as Vodka, not for whiskey.

3.8 Additional Notes 

General Food

None.

Category

Alcoholic beverages 

None.

Product

Whisky

Same as "Category" above.

3.9 References

1. Regulation(EC) 1334/2008 of the European Parliament and of the Council of 16 December 2008 

http://data.europa.eu/eli/reg/2008/1334/2025-02-19

2. Regulation (EC) 1333/2008 of the European Parliament and of the Council of 16 December 2008 

http://data.europa.eu/eli/reg/2008/1333/2024-12-16

3. Regulation (EU) No 231/2012 of 9 March 2012 

http://data.europa.eu/eli/reg/2012/231/2025-04-27

4. Regulation (EU) 2019/787 of the European Parliament and of the Council of 17 April 2019

http://data.europa.eu/eli/reg/2019/787/2024-05-13

5. Regulation (EC) 852/2004 of the European Parliament and of the Council of 29 April 2004

http://data.europa.eu/eli/reg/2004/852/2021-03-24

6. Regulation (EC) No 1925/2006 of the European Parliament and of the Council of 20 December 2006 

http://data.europa.eu/eli/reg/2006/1925/2024-07-17