In an ongoing effort to disprove the good-intentioned but flawed “Rum has no rules” sentiment, a number of rum experts have repeatedly and forcefully worked to shoot it down. Specifically, by highlighting actual legal documents defining exactly what the “standard of identity” is for various rum producing countries. Here, we’ll look at the regulations for Jamaican Rum.
In a nutshell, countries can choose to define a set of regulations that must be followed if a product is to legally include specific wording on their labels. For example, Scotland defines rules that must be followed for a bottle to be labeled “single malt scotch whisky”. Likewise, France has rules for “Cognac” and “Armagnac”. In the rum world, the most famous regulations are the Appellation d’Origine Contrôlée for Martinique rum.
Different countries have different formal names for their regulations. However, in general usage, they’re known as Geographical Indications, or “GIs”, which is what I will use here. The geographical part of the name refers to the fact that the regulations have geographical scope, e.g. Cuba for Cuban rum, Brazil for Cachaça, and so forth.
I’ve written about many cane spirit GIs – The full list is here: Geographical indication Archives
In this article, I’m digging into Jamaica’s recently approved rum GI. Mercifully, it’s already in English so I don’t have to translate it first! (Disclaimer: The documents I’m working from appear to be from 2016. It’s entirely possible that the Jamaican producers have evolved the GI since then.)
Typically, GIs are long, boring, and filled tons of details not relevant to the casual reader. As such, I have prefaced the full text with my summarized version. The full text is found at the end of this article.
Overall Commentary
Jamaica’s rum regulations aren’t particularly onerous or restrictive. They follow “common sense” best practices that most top tier rum producers already use. Compared to Cuba and Martinique’s regulations, Jamaica’s seem less restrictive, but still cover all important points.
However, a very interesting point is that there are no specific reference to post-distillation sugar, sweet wine, or other additives. That is, the document does not specifically disallow what some call adulteration. However, the Jamaican Excise Duty Act does have this to say:
34. -(1) Except as may be otherwise permitted by the Commissioner, nothing shall be added to any spirits in a distillery save colouring matter or water. (Reference 17/1971 S.8. 12/1985 Sch.)
A hat tip to Richard Seale for finding that one.
Jamaican Rum – The Simplified Rules
Article 1
In order for a label to bear the wording “Jamaica Rum”, the rum’s production must be as follows:
The rum wash (mash) must be made using naturally filtered limestone water from the region defined in article 2 (below).
Besides water, the fermented rum wash may contain:
- sugar cane molasses
- juice of sugar cane
- crystallized cane sugar
- sugar cane syrup
- a mixture or combination of the above.
Commentary: Note that there’s no requirement to use Jamaican-grown sugar cane. Jamaica has needed to import some of its molasses in recent years.
Article 2
Fermentation and distillation must occur in the territory of the limestone Aquifer water basins shown in Annex 1 (below).
Commentary: Like Martinique, Jamaica limits production to certain areas of the island. However, the allowed areas are roughly 50% of Jamaica’s land area.
Article 3
The rum wash must be made with the raw materials used in Article 1, with filtered limestone water from the geographical area.
Commentary: This seems to be restating Article 1 in a different way.
Article 4
Fermenting agents are limited to Saccharomyces type yeasts. Inoculation of the wash may only be carried out by cultured yeast, commercial yeast or naturally occurring yeast in the environment.
Commentary: Both commercial yeast and “open” natural fermentation are allowed.
Article 5
Pot and column stills are allowed. Pot stills must be copper, and the rectifier portion of the column still must be copper.
Article 6
All rums must be made available for analytical and sensory examinations by the JRASTA technical committee, which issues certifications annually. Rums must conforms to the specifications of sensory tests, supported by gas chromatography or mass spectrometry.
Commentary: While these requirements sound vague, there is a mind-numbing document describing the specific chemical analysis and organoleptic tests to be done. We shall not go down that rabbit hole.
Also: JRASTA – Best committee name EVER!
Article 7
After distillation, rums with the Geographical Indication “Jamaica Rum” be in one of these categories
- Non-aged rums
- Rums aged in small wooden oak barrels.
Rum shall have no color except for coloring from oak wood aging or from cane sugar caramel.
Commentary: Note that only “oak” is specified, without regard to subtype, like American oak or French oak. This provides substantial leeway in cask selection. Also note that both new and previously used casks are allowed.
Article 8
An age statement must be certified by the Jamaican Excise Officer.
Article 9
Rum can only be moved to a rum store or excise warehouse, and must be under excise supervision.
Article 10
GI compliant rums must say “certified Geographical Indication” on the label and all other related documents.
The label’s age statement must be in terms like “___ years old”. When an age is stated, it must be the youngest rum in the blend.
Article 11
Producers of rum who sell Jamaica GI labeled rum that doesn’t meet the requirements will be prosecuted.
If GI-compliant rum is blended with non GI-compliant rum, the resulting rum cannot use the GI labeling.
Article 12
Immediately after these regulations go into effect, producers have a window for which they can apply to have their existing stocks labeled with the “Jamaica Rum” designation, assuming certain documentation procedures are followed.
The unabridged Jamaica Rum Regulations
Jamaica Rum – Code of practices
Art. 1. – Definition:
Only rums obtained by distillation using wash produced with naturally filtered limestone water obtained from the geographical area defined in Article 2. The fermented wash shall be produced using sugar cane molasses, juice of sugar cane, crystallized cane sugar, sugar cane syrup and or a mixture or combination of the above which comply with the conditions of the present code are entitled to the Geographical Indication “Jamaica Rum”.
Art. 2. – Geographical area:
The region for the fermentation and distillation of rums entitled to the Geographical Indication “Jamaica Rum” is limited to the territory of the limestone Aquifer water basins, as figured in the map in annex 1.
Ageing is entitled to the protected geographical indication “Jamaica Rum” which complies with the conditions of production defined in the subsequent articles 7 & 8. This shall be carried out in Jamaica, and approved by the GI Jamaica Rum and Spirits Traders Association (JRASTA)
Art. 3. – Raw material:
Sugar cane wash is prepared by reducing any of the raw materials used in Article 1 with filtered limestone water from the geographical area.
Art. 4. – Fermentation:
Fermentation takes place in designated vessels termed as fermenters.
The addition of fermenting agents is limited to the yeasts of Saccharomyces types only. The inoculation of the prepared wash may only be carried out by cultured yeast or by commercial yeast or from naturally occurring yeast in the environment. GMO yeasts are strictly prohibited.
Fermentation is complete when all fermentable cane sugars referred to in Article 1 have been converted into component parts.
Art. 5. – Distillation stills:
Pot stills must be copper. Column stills rectifier must be copper.
Art. 6 – Product Analysis:
All Rums (Marks or Brands) must be presented for analytical and sensory examinations prior to the issuance of an approval certificate. Chemical and sensory examinations are performed according to the procedures specified in the Control Handbook. The certificate of approval is issued annually by the Jamaica Rum and Spirits Traders Association (JRASTA) Technical Committee, where the Rums (Marks or Brands) conforms to the specifications of Organoleptic Tests, supported by gas chromatography (GC) or mass spectrometry (Mas Spec).
Art. 7. – Finished product:
At the end of distillation, the rums which claim to Geographical Indication “Jamaica Rum” should fit into one of the following categories:
– “non aged” rums requires no ageing.
– “aged” rums are aged in small wooden oak barrels and warehoused under the Jamaican Excise office supervision.
Rums must be produced in accordance with the distillation certificate.
Rum shall be colourless except where the colour is derived from oak wood during maturation or from caramel produced from cane sugars.
Art. 8. – Rum stored in oak wood – minimum aged:
The minimum age of these rums being stored in a barrel made of oak wood must be certified by the Jamaican Excise Officer.
Art. 9. – Transportation:
The rums for which the Geographical Indication “Jamaica Rum” is claimed, must be moved in accordance with the excise law
All rums manufactured are moved to a rum store or an excise warehouse under excise supervision.
Art. 10. – Labelling:
The rums for which, in the terms of the present code, the protected Geographical Indication “Jamaica Rum” is claimed, cannot be declared for production, offered to consumers, dispatched or sold without the designation being clearly and visibly noted and accompanied by the words “certified Geographical Indication” on the declaration of manufacture, the transport documents, prospectuses, labels, invoices and any receipts and any other document used in the trade of the products..
A statement of age may be given on the label in terms such as “___ years old”. Where a statement is given, the age stated shall be that of the youngest rum in the blend.
Art. 11. – Misuse:
The use of any indication or sign which may cause a buyer to believe that a rum has the right to use the protected Geographical Indication “Jamaica Rum”, although it does not satisfy all the conditions defined in the present decree, will be prosecuted according to the general legislation concerning fraud and the protection of the designations of origin, irrespective of fiscal sanctions if such exist.
Once rum with a right to the use of the protected GI designation “Jamaica Rum” is blended with a non GI component that end product loses the right to use the GI “Jamaica Rum”
Art. 12. – Transitory measures:
The producers and owners of stocks of rum with the Geographical Indication “Jamaica Rum” may, within a period of four months after the publication of the present decree, apply for the approval of their production and stock with Geographical Indication “Jamaica Rum” from the date of certification.
All Jamaica rums in storage outside of Jamaica will require independent audit verification by International Auditors (For e.g. PricewaterhouseCoopers, KPMG and SGS) prior to approval as Jamaica Rum G.I. For Bulk Jamaica Rums evidence of the following documents must be made available for scrutiny:
- Distillation Certificate
- Country of Origin
- Transfer control Document (document that allowed movement of rum into bulk stores)
For Blended (finished) Jamaica Rums, evidence of the following documents must be made available
for scrutiny:
- Excisable goods received form noting receival of goods into the blending hall/stores
- Document allowing movement of product into bottling hall (production)
- Document allowing movement of product from bottling (production) into Finished Goods Excise Warehouse
The certificate of approval will be issued by the Government of Jamaica Excise Officer after these rums have satisfied the demands of the analytical examinations, according to the procedure defined by the code relating to the approval of rums with Geographical Indication.
The reality is that there are no rules for rum. There may be rules for Jamaican rum, or Martinique rum, or any number of other geographical indications, but it would be inaccurate to say that there a rules for the production of rum generally. Beyond the fact that it must be made from sugar cane, or its byproducts, there is no regulations for making rum.
The fact that Jamaica’s rules are so different from those in place in Martinique or Cuba illustrate the point. The result is two very distinct and contrasting spirits. Jamaican rum not only tastes different than the others, it is produced very differently.
Contrast this with Scotch, Cognac, Armagnac or Champagne that must be made in accordance with strict guidelines in order to legally bear their respective names. The result here are classifications of spirits that are almost indistinguishable. While there may be some small identifying characteristics from producer to producer, most Scotches are alike. Certainly, there is not the wide range of Scotches as there are rums.
On top of this, there are countless companies making rum in countries where there is no regulation on production. Many import molasses or raw or finished product from other countries and put their own spin on the finished product.
The whole counter-argument to the “rum has no rules” position is borne out of an attempt by some producers to make their product more exclusive and, consequently, dear. I understand the desire to be recognized for employing traditional methods, but the creativity and variety of available flavours and styles rum is what makes rum a superior spirit to all others.
Devin,
You write eloquently and you’re making my point.
What if I said “Whiskey has no rules”? You’d say that’s not true. There are rules for Scotch Whisky, and American Bourbon. But those are both whiskies.
What if I said “Brandy has no rules”? You’d say that’s not true. There are rules for Cognac, Armagnac, and Pisco.
Rum is an uber-category, like Whiskey, like Brandy. The critical difference is that the consumer has been educated to understand that there’s a difference between Scotch whisky and American bourbon. That hasn’t happened yet with rum.
So when you say *single malt scotch* whisky is a distinct style and has rules, I will say “Martinique rhum” is a distinct style, and has rules too.
When you say “there are countless companies making rum in countries where there is no regulation on production”, could you not say the same for whiskey?
When you say ” Certainly, there is not the wide range of Scotches as there are rums.” I would point you to Martinique AOC rhums, which also have a very similar flavor profile.
We have to compare apples to apples here. And step one is getting people to understand “what is an apple” vs “what is a fruit”.
Finally, I’ll point readers to my earlier post on exactly this topic: https://cocktailwonk.com/2017/06/rum_has_no_rules.html
You make a number of points that are fair and accurate. I think I agree with you.
The only point I would make is that the opponents of the “rum has no rules” position compare rum wistfully to Scotch, not whiskey. My sense is that they want to stamp out the use of the word ‘rum’ to describe anything that doesn’t follow a strict set of rules. This is certainly the feeling I get from Richard Seale. Unless a producer follows the same traditional distilling methods he uses, the product is not worthy of being called rum.
I disagree with Seale and his followers in that I welcome new methods and creative ways of making rum. That isn’t to say I enjoy all rums or that I don’t have favourites, just that I think they all have value (as long as they are made from sugar cane or its byproducts).
Great work on this website by the way. It’s by far the best source of intelligent discussion about rum on the internet.
Thanks Matt, this is very interesting. Do you have a sense of the enforcement regimes that are in place in Jamaica and in other countries? Are the monitoring results somehow disclosed to the public? Or are there any known cases of prosecution?
Great question. I really don’t know the enforcement angle. It’s likely not so hard to get in-country enforcement. The hard part is getting other countries to respect your GI. America respects the Scotch and French GIs, and they in turn respect America’s. But as we’ve learned, even if America recognized the Jamaican GI, the U.S. TTB is completely unequipped to judge and enforce it.
A rum aged outside Jamaica could use the Gi Jamaica on the label? If yes is the biggest owngoal
Is there any link to the official document? Can’t find that regulations
Not that I’ve seen. A little surprising.?♂️
Hi Matt, great reading as always.
I know I’m a little behind the times, but a question has just came up – what about the term ‘Jamaican Rum’? I notice Hampden Estate use this. Should we presume that, If it is labelled ‘Jamaica Rum’, then the GI applies, but if it is labelled ‘Jamaican Rum’ the GI conditions are not a legal requirement?
Great question. I don’t know if the extreme similarity between Jamaica and Jamaican is enough (legally) to consider them both covered. It might be a matter for the intellectual property court.