What Should a “Pennsylvania Rye Whiskey” Category Look Like Today?

This has been an ongoing debate for a while now…even if it should have been a debate that took place in the 1930s. (Hindsight is 20/20 they say…) The question posed is- “Should Pennsylvania rye whiskey have its own category in the American liquor industry?” Now, before giving any of my personal thoughts on answering this (I will), let me begin by saying that the idea of a category for spirits is a relatively new concept for the American spirits industry. We take for granted that the TTB has legal standards of identity. You’ve got your neutral spirits, vodkas, gins, rock & rye, scotch, cordials and liqueurs, brandies, etc… and your whiskeys. These each have subcategories or “types”. Whiskeys can be corn whiskeys, straight whiskeys, light whiskeys, spirit whiskeys, bourbon whiskeys, rye whiskeys, whiskeys distilled from specific mashes…and the list goes on. What we tend to NOT know is that these distinct categories did not exist at all until 1935, were not law until 1936, and have evolved to mean different things over time. The standards of identity were created by FDR’s newly formed Federal Alcohol Administration (FAA) in cooperation with the Departments of Agriculture and Treasury. The FAA’s mandate was to collect data, to establish license and permit requirements, and define the regulations that ensure an open, fair marketplace for the alcohol industry and the American consumer. Rye whiskey held its own sub-category under the class of “whiskey,” while bourbon and corn whiskey were listed together under the same subcategory. It may seem odd to a modern whiskey drinker that rye once took precedence over bourbon, but it most certainly did. I do not say this to disparage bourbon, I say it to help explain that these categories were only ever made to establish fair trade and consumer protection from mislabeling or fraud. The industry could not have known what the future would hold for American whiskey. Today, the industry finds itself in unchartered territory.

Before Prohibition, standards of identity were controlled and maintained by the industry itself. A balance was tentatively achieved between the government regulators and the manufacturers. Quality was maintained through a high degree of competition in the marketplace paired with strict regulations and oversight provided by the Department of Revenue. There were over a hundred distilleries operating in Pennsylvania before Prohibition and about 35 operating immediately after. There are many reasons that Pennsylvania did not survive Prohibition as it should have, but that is a complicated narrative and can be read about more HERE. The point is that rye whiskey was highly respected, highly sought after, and very valued within the trade. It’s standard for identity rested on consumer trust in “pure rye whiskey” and on the desire of rye whiskey producers to maintain their dominance in the trade.

“Pure rye whiskey” was understood within the trade to mean that the whiskey in the barrel and in the bottle was unadulterated by any rectification or dilution. Pennsylvania distillers only began to use the term “straight” in the 1890s after it gained favor with consumers and after outside interests began to invest heavily in Pennsylvania rye whiskey distilleries. “Straight,” like “pure rye” was a term (not a legal definition) used by producers to describe whiskey straight from the barrel. The “straight whiskey interests” had a powerful lobby and were gaining momentum in the trade. Rye whiskey producers embraced the term “straight” when it suited them. While Pennsylvania’s rye whiskey distilleries were spread across the state and usually located in the countryside, their owners usually kept home offices in Philadelphia and Pittsburgh. It was in these two cities that owners maintained their vast business networks. They also organized meetings and consolidated their lobbying power to maintain the integrity of rye whiskey. Perhaps the need for a defined category for rye whiskey was unnecessary because these men had been slowly building empires for 100 uninterrupted years and had no need for protection from anyone larger than themselves. Even when the Whiskey Trust reformed in 1895 as the American Spirits Manufacturing Company and created the Kentucky Distilleries and Warehouse Co. as a subsidiary, Pennsylvania’s rye whiskey distilleries rejected their buyout offers and went on with their businesses. Rye whiskey remained the most valuable American whiskey on the market before, during, and even after Prohibition. With all the research I have done into Pennsylvania’s distilleries, I believe that the most significant reason that PA was not able to survive Prohibition was that they were not protected by corporate consolidation as the Kentucky distilleries had been. There is a lot of history here, but suffice it to say that Pennsylvania’s distilleries limped away from Prohibition. They were not finished off yet, but they would not recover after losing their unified front of independent ownerships. Now, here we return to the unchartered territory of the present. There are now in Pennsylvania nearly as many individual distilleries as there were before Prohibition. Believe it or not, there are about 140 active distilleries in PA in 2022. But the differences are obvious. Boundless history, much older than that of any other American whiskey, has inspired so many small businesses to begin making rye whiskey in the Keystone State again. Allowing them to once again own their own history and attach their products to this lost legacy would be invaluable to Pennsylvania’s modern distilleries.

So what differentiated Pennsylvania whiskey historically from other distilleries making rye whiskey in America? There was rye whiskey being made in many other US states, but Pennsylvania rye was in its own class. This trade prestige was won slowly and over the course of many generations. Pennsylvania rye whiskey was the original specialty whiskey in America. People sought it out because they knew that the best rye whiskey had always been made here. Before advertising or labels, taverns and hotels and saloons were able to mark up the “old rye” they served to their customers. It sold itself. When advertising of products to consumers became more commonplace in the mid-19th century, “Old Monongahela,” “Old Rye Whiskey” and “Pennsylvania Pure Rye Whiskey” became trusted label designations for retail products. That trust never went away, either. Even when you look at the significance of which brands were bought up during Prohibition by the few corporate entities that controlled America’s whiskey stocks- which brands did they use for their medicinal whiskeys? “Pure Rye Whiskey” and “Pennsylvania Rye Whiskey” held the public’s fascination even after the distilleries themselves were gutted and demolished and the families that originally owned the brands were long gone. It still does. Otherwise, why would a Kentucky distillery have turned over their rye whiskey production to a Pennsylvania distillery in the 1970s and 80s when so many KY distilleries were capable of doing so? Why would a Kentucky bourbon want to name its entire product line after a defunct Pennsylvania rye distillery? Why would the largest producer of American whiskey in the country use a Pennsylvania brand as a core product and advertise its historic connection to Pennsylvania with so much effort and at so much cost? The fact is that the best rye was made here, and the distilling industry remembers that even if consumers do not. There are no books on the history of American whiskey production that do not give credit to Pennsylvania rye whiskey- where that credit is due.

Now what were the differences in production? If we look at the process itself, almost everything was different. Let me begin by saying that each rye whiskey distillery was unique unto itself. Just as today, distilleries had to operate within a large field of competitors and having a unique product was important. Let’s look at the following stages of production and how they may relate to modern Pennsylvania rye whiskey: 1. Grain- farming and agriculture, malting, and milling; 2. Mashbill and cooking the mash; 3. Yeast and fermentation; 4. Still design and distillation; 5. Warehousing and barrel aging.

1. Grain
Farming and Agriculture

While Pennsylvania rye whiskey was building a reputation for excellence in the late 18th and early 19th centuries, all the rye grain used in the distilleries was grown locally- usually within the same county (or neighboring county). This was usually because distillers tended to be wealthy landowners and/or millers who owned the land from which the rye crops were harvested. Even as the scale of operations within the state developed, rye was still grown within the state (mainly in the southeast) even as more rye began to be imported from Ohio, Michigan and the Red River Valley to supplement demand.

While the amount of rye grown in Pennsylvania has been reduced to historically low amounts, modern distillers may find that sourcing rye grain locally is still possible. Production levels TODAY are comparable to Pennsylvania distilleries from the early 1800s. That may be due to smaller batch sizes or inconsistent production schedules, but the fact remains that most new distilleries use tens of thousands of pounds of grain per year and not the millions that were once consumed. Today, farmers could once again benefit from the restoration of these traditional and very lucrative business relationships- distillery and farmer, together, as partners, growing together. As the distiller needs more grain, the farmer can expand their acreage, and both can benefit from the transaction…even if it may require a little improvement in their communication. After all, it’s been a hundred years, and they’ve been out of touch. Each could use a detailed reintroduction to the other and a crash course into what each requires from the other!

2. Mashbill
Cooking the Mash

Pennsylvania rye whiskey mashbills varied widely, but rye grain was almost always the main ingredient. Large rye whiskey distilleries also produced malt whiskeys and wheat whiskeys, but the core product remained rye whiskey. Everyone knew that location was their most marketable asset. In fact, in the 1890s, outside interests began buying land in the Monongahela Valley just because the provenance of the whiskey had become so important in the marketplace. Protecting the legitimacy of your brand had become a necessity with such a crowded field of rye whiskeys on the market, and salesmen knew that their customers were wise to falsehoods and imitations. Production location was more important than the contents of the mashbill. While our modern American mindset does not put much thought into a whiskey’s provenance, the pre-pro mindset was very similar to the one that we associate more closely with Europe. Location was everything.

“Rye and malt” usually meant rye and rye malt until Pennsylvania’s brewers made barley malt more financially viable for distillers. Thomas Moore’s Old Possum Hollow rye whiskey was described by Thomas Moore, “the pioneer distiller” himself, in the late 1870s as being 50% rye and 50% malt. This was based on his tried-and-true recipe that he had been using since the 1840s which makes it much more likely that the “malt” in his recipe was rye malt. Barley was never a large crop grown in Pennsylvania, and the mashbills (whiskey recipes) would have reflected that- at least early on. The fact that Moore’s mashbill was 50/50 also lends credence to this theory because a higher percentage of rye malt would have provided plenty of enzymatic conversion power for the mash. Before Prohibition, the rye varieties that were being used had higher protein content and they would have had higher conversion rates anyway.

As railroads made imported grain more available and large distillers added their own malt house facilities in the late 1800s, costs came down and “rye and malt” began to mean rye and barley malt. We tend to think that barley malt was a given- that Pennsylvania rye whiskey or Monongahela Rye whiskey was mostly unmalted rye with a percentage of malted barley added to the rye for its conversion power- but Pennsylvania rye whiskey is much older than the advent of industrial malt houses or the availability of barley to Pennsylvania’s distillers. We must remember that while the expense of using barley malt might have been an option for a small brewery, it would not have been for a distiller. Not only can much more beer be produced from the same amount of malted barley, but much more volume could be sold for immediate profit. Whiskey requires more grain to produce less product and takes years to mature! The boom in growth of Pennsylvania’s brewing industry in the late 19th century made barley much more available and helped to make barley malt much more cost effective for distillers. Distillery owners built their own malting facilities on site, invested in breweries, and took advantage of the railroad’s adjusted shipping rates. These distinctions are important because it helps to explain how rye whiskey’s ingredients evolved over time. The mashbills may have changed, but the commitment to excellence and the willingness to spend money to make a higher quality product never wavered.

Once the grain arrived at the facility and was approved by quality control, it was cleaned and brought into the distillery, malted or unmalted, and fed into the mill. The size of the distillery determined how this was done, but generally, the distillery milled its own grain using roller mills because they were compact, consistent machines that didn’t require too much maintenance. Grain amounts were closely monitored by a government gauger from the moment the grain entered the facility. Measurements were taken before and after the grain entered the mashtun for cooking. Because rye whiskey was sweet mashed, water was added to the mashtun instead of backset. The mash was cooked in large, steam-heated cookers for several hours- depending on what grains were being cooked. If corn was part of the recipe, the time was longer and the initial temperature used was higher.

The differences between how bourbon mashes and rye whiskey mashes were cooked and fermented was quite different. This was known within the industry and is why distillers were so specialized in their fields of expertise. In fact, with a highly competitive whiskey market, the rye distillers were forced to form a lobbying group in 1869 to protect their unique processes from being held to the same standards of other whiskey producers. The Internal Revenue Department attempted to standardize fill levels and fermentation times for all distillers, and rye whiskey men formed a commission to explain why their methods were different and needed room to remain so. Temperatures for cooking are lower for rye, fill levels were lower to prevent overflow during fermentation, and fermentation times differed depending on the grains and malt used in the mashbills. Each distillery used different methods to create their unique products and needed to be given the allowances to do so. They were successful, by the way- thankfully, the standards sought were not implemented and the rye manufacturers were able to continue their unique process.

Today, Pennsylvania rye whiskey distillers are still coming into their own. They are still discovering what separates their process from the rest. The nature of rye grain forces a distiller to reevaluate their decisions on everything- from milling, to the percentage of malt used, to what type of equipment best suits their needs. I have yet to meet a rye whiskey distiller in Pennsylvania that has not expressed to me how they’ve had to reevaluate their production process since they began in the business. (I’ve met and talked with at least 50 of PA’s current distillers.) The idea that a specific mashbill should be placed upon what it means to be a Pennsylvania rye whiskey should not be more than what the government has already put in place. That is, at least 51% of the recipe must be rye- without any distinct variety necessary.

3. Yeast and Fermentation

Pennsylvania distillers, like most “pure rye” or “straight whiskey” distilleries before Prohibition, had great pride in their yeast strains. Almost every distillery had a separate “yeast room” where the yeast was propagated and kept in isolation. Distillers had expertise in culturing and caring for yeast. The practice of maintaining a yeast strain was as old as the practice of whiskey distillation, so its mastery was highly respected within the trade. As distilleries grew in size, special management job positions were created specifically for the distillery’s chemist whose job it was to preserve and maintain the yeast. Pennsylvania rye whiskey had always been made with a sweet mash- with very few exceptions. This meant that each mash was prepared identically with fresh grist and fresh yeast. The yeast was pitched into cooked mash as it was pumped from the mashtun into large, wooden vats for fermentation.

4. The Still and Distillation

The beer still was usually a chambered still, though pot stills were still very common, even up until Prohibition. Somerset County, for instance, remained famous for its fire-heated, double copper pot still distillations of pure rye whiskey into the 20th century. Here is a description of the chambered stills-

“Two, three or more chamber charge-stills, with or without charging chamber in one apparatus, in which the single compartments are placed one over the other, and the heat from the lower serves to enrich the one above. Steam is used for heating. All these apparatus, when heated by direct firing, are made either of copper or iron; when heated with steam are made generally of copper, but ofttimes of wood, such as heavy cypress or white oak. These are more suitable for intermittent working, and are used mostly in distilleries which distil rye whisky, etc.”
(excerpt written by Richard Ferris, C.E., Sc.D. for The Encyclopedia Americana, 1923.)

Most distilleries, especially the large distilleries, had a set up like this: A large copper or wooden chambered still served as a beer still where fresh mash could be pumped for initial distillation. A smaller copper doubler acted as a spirit or refining still. The alcohol vapor was condensed through a long, copper worm which wound through a large flake stand outside of the still house. When the worm was not present, a condenser was used. The finished distillate ran through a separator (separates high wines and low wines) and, finally, into a cistern. While this was the normal template for some of the most famous rye whiskeys made in Pennsylvania, these methods had not been revealed to the public (or, more importantly, to the distillers themselves) until fairly recently. Most of the modern distilleries in Pennsylvania have designed their distilleries after an older, pot still style of Pennsylvania rye whiskey. This is no less accurate, historically. The thing that was completely absent from Pennsylvania rye whiskey distilleries until after Prohibition was the column still. There was only one column still present among the 150+ distilleries that I have researched, and that example did not show up until after 1905. It was brought in by out-of-state interests. This is not to say that column stills did not become the norm after Prohibition. But even when they were embraced for their increased efficiency, the column still simply replaced the chamber still as the beer still, and it was operated as such. The doubler and the condenser remained an important part of the process.


You see, while most Americans may not realize it, Pennsylvania was home to some of the most famous whiskeys ever made in this country. It’s not even ancient history! Even today, some of the most recognized brands of rye whiskey were born in the Keystone State. Modern brands like Rittenhouse Rye, Old Overholt Rye, Highspire Rye, Kinsey Rye, Meadville Rye, and Michters Rye earned their fame in Pennsylvania. Right up until Prohibition, Pennsylvania’s thriving rye whiskey empire was content to rest on its laurels- even as it avoided the onslaught of proposed buyouts and corporate takeovers. And they were doing so well at maintaining their independence that when Prohibition did hit the industry with a sledgehammer, their independence became a flaw- leaving them without the unified shield necessary to sustain the impact. After 100 years, however, a renaissance is underway. The rules are different, but the game is at least allowing Pennsylvania distillers to play again.

Pre-Prohibition brands like Guckenheimer Pure Rye, Gibson’s Pure Rye, Dougherty’s Pure Rye, Bailey’s Pure Rye, and Thomas Moore’s Possum Hollow rye were made famous even after Prohibition. Sam Thompson’s Rye and Old Vandegrift Rye may not be around anymore, but many of us may remember them from our parent’s liquor cabinets. One of the weaknesses in the modern argument for Pennsylvania’s rye whiskey as a category is that we lack the general knowledge to support it. We often see Old Overholt praised as a guide for what Pennsylvania rye whiskey once was- as the quintessential  pre-Prohibition rye whiskey. And yes, Old Overholt was a very well-known brand, but it was only made more so by National Distillers, the largest owner of whiskey stocks after Prohibition. The Overholts didn’t start their distillery at West Overton until 1810 and the brand “Old Overholt” didn’t exist until 1888 when Charles Mauck introduced it using whiskey distilled at the company’s modern Broad Ford plant. Not that that fact belittles the impact of the brand’s excellence, but it was not the highlight of Pennsylvania’s rye whiskey legacy. Nor was it the only example of what Pennsylvania rye whiskey had been. It was a survivor, for sure, but it was only one among hundreds of unique brands. “Old Monongahela” rye whiskey was a regionally recognized style, but so was “Susquehanna rye whiskey,” an older traditional style of rye whiskey from the eastern part of the state. The unifying characteristic of Pennsylvania rye whiskeys was provenance. It is what makes Speyside whiskey or Islay whiskey from Scotland unique. It is what makes Irish whiskey unique. There are specific identifying characteristics that these whiskeys often possess (peated, unpeated, malted or unmalted grain, etc.) but they are not universal. There are exceptions, as there should be. Pennsylvania’s Moore & Sinnott Distillery toasted their unmalted grain AND their malted rye before it was mashed in. Does using toasted rye grain make them unique? Yes! Does it make their rye whiskey any less Monongahela rye whiskey? Absolutely not. If history can serve as a guide, we should allow modern distillers the same freedom their predecessors were given. If they want to add wheat or corn or specialty grains to their mash, it should not be excluded from being considered “Pennsylvania rye whiskey.”

I believe that having 250 years of distilling tradition and a legacy of excellence to draw from should qualify Pennsylvania rye whiskey with a category distinction today. However, before we go making decisions on what qualifies a rye whiskey as being a “Pennsylvania rye whiskey,” perhaps we should all look a bit closer at what Pennsylvania rye used to be. Not only should more credit be given to what it once was, but also to what it has become and to what it still has in store for future generations. A new category of rye whiskey should certainly be granted to Pennsylvania. Let’s just make sure it doesn’t exclude variations within the category. History shows us that Pennsylvania rye whiskey had many variations, but its most enviable quality throughout the industry was simply that it was exclusively made here. In Pennsylvania. After all, the only historically defining characteristic of ALL Pennsylvania rye whiskey was rye grain…and provenance.


For those curious, the first time “rye whiskey” (or any whiskey) was defined by the US government was in 1935. These are the definitions of whiskey as defined by the FAA. Note that rye was defined before other variations. There was no distinct classification for Pennsylvania rye whiskey, but rye whiskey is always given priority.

Class 2: Whiskey

  • Whiskey is an alcoholic distillate from a fermented mash of grain distilled at less than 190 proof in such manner that the distillate possesses the taste, aroma, and characteristics generally attributed to whiskey, and withdrawn from the cistern room at not more than 110 and not less than 80 proof, whether or not such proof is further reduced prior to bottling to not less than 80 proof and also includes mixtures of the foregoing distillates for which no specific standards of identity are described herein. Rye whiskey, bourbon whiskey, wheat whiskey, corn whiskey, malt whiskey, or rye malt whiskey is whiskey which has been distilled to not exceeding 160 proof from a fermented mash of not less than 51% rye grain, corn grain, wheat grain, malted barley grain or malted rye grain, respectively, and also includes mixtures of such whiskeys where the mixture consists exclusively of whiskeys of the same type.
  • Straight whiskey is an alcoholic distillate from a fermented mash of grain distilled from a fermented mash of grain distilled at not exceeding 160 proof and withdrawn from the cistern room at not more than 110 and not less than 80 proof, whether or not such proof is further reduced prior to bottling to not less than 80 proof, and is-
  • Aged for not less than 12 calendar months if bottled on or after July 1, 1936, and before July 1, 1937; or
  • Aged for not less than 18 calendar months if bottled on or after July 1, 1937, and before July 1, 1938; or
  • Aged for not less than 24 calendar months if bottled on or after July 1, 1938.


The term “straight whiskey” also includes mixtures of straight whiskey, which, by reason of being homogeneous, are not subject to the rectification tax under the Internal Revenue Laws

  • Straight rye whiskey is straight whiskey distilled from a fermented mash of grain of which not less than 51 % is rye grain.
  • Straight bourbon whiskey and straight corn whiskey is straight whiskey distilled from a fermented mash of grain of which not less than 51 % is corn grain.
  • Straight wheat whiskey is straight whiskey distilled from a fermented mash of grain of which not less than 51 % is wheat grain.
  • Straight malt whiskey and straight rye malt whiskey are straight whiskey distilled from a fermented mash of grain of which not less than 51 % is malted barley or malted rye, respectively.
  • Blended whiskey (whiskey-a blend) is a mixture which contains at least 20% by volume of 100 proof straight whiskey and, separately or in combination, whiskey or neutral spirits, if such a mixture at the time of bottling is not less than 80 proof.
  • Blended rye whiskey (rye whiskey- a blend), Blended bourbon whiskey (bourbon whiskey- a blend), Blended corn whiskey (corn whiskey- a blend), Blended wheat whiskey (wheat whiskey- a blend), Blended malt whiskey (malt whiskey- a blend) or Blended rye malt whiskey (rye malt whiskey- a blend) is blended whiskey which contains not less than 51% by volume of straight rye whiskey, straight bourbon whiskey, straight corn whiskey, straight wheat whiskey, straight malt whiskey, or straight rye malt whiskey, respectively.
  • A blend of straight whiskeys (blended straight whiskeys), a blend of straight rye whiskeys (blended straight rye whiskeys), A blend of straight bourbon whiskey (blended straight bourbon whiskeys), A blend of straight corn whiskeys (blended straight corn whiskeys), A blend of straight wheat whiskeys (blended straight wheat whiskeys), A blend of straight malt whiskeys (blended straight malt whiskeys) or A blend of straight rye malt whiskeys (rye malt whiskey- a blend) are mixtures of only straight whiskeys, straight rye whiskeys, straight bourbon whiskeys, straight corn whiskeys, straight wheat whiskeys, straight malt whiskeys, or straight rye malt whiskeys, respectively.
  • Spirit whiskey is a mixture (1) of neutral spirits and not less than 5% by volume of whiskey, or (2) of neutral spirits and less than 20% by volume of straight whiskey, but not less than 5% by volume of straight whiskey, or of straight whiskey and whiskey, if the resulting product at the time of bottling be not less than 80 proof.
  • Scotch whiskey is a distinctive product of Scotland, manufactured either in the Irish Free State or in Northern Ireland, in compliance with the laws of those respective territories regulating the the manufacture of Irish whiskey for consumption in such territories, and containing no distilled spirits less than three years old: Provided, That if in fact such product as so manufactured is a mixture of distilled spirits, such mixture is Blended Scotch whiskey (Scotch whiskey- a blend). Scotch whiskey shall not be designated as straight.
  • Irish whiskey is a distinctive product of Ireland, manufactured in Scotland in compliance with the laws of Great Britain regulating the the manufacture of Scotch whiskeyfor consumption in Great Britain, and containing no distilled spirits less than three years old: Provided, That if in fact such product as so manufactured is a mixture of distilled spirits, such mixture is Blended Irish whiskey (Irish whiskey- a blend). Irish whiskey shall not be designated as straight.
  • Canadian whiskey is a distinctive product of Canada, manufactured either in Canada, in compliance with the laws of the Dominion of Canada regulating the the manufacture of whiskey for consumption in Canada, and containing no distilled spirits less than two years old: Provided, That if in fact such product as so manufactured is a mixture of distilled spirits, such mixture is Blended Canadian whiskey (Canadian whiskey- a blend). Scotch whiskey shall not be designated as straight.
  • Blended Scotch type whiskey (Scotch type whiskey- a blend) is a mixture made outside Great Britain and composed of-
    (1) Not less than 20% by volume of 100 proof malt whiskey or whiskeys distilled in pot stills at not more than 160 proof, from a fermented mash of malted barley dried over peat fire, whether or not such proof is subsequently reduced prior to bottling to not less than 80 proof, and

(2) Not more than 80% by volume of whiskey distilled at more than 180 proof and less than 190 proof, whether or not such proof is subsequently reduced prior to bottling to not less than 80 proof.
In Lieu of including the word “Type”, the designation may include the word “American” at the beginning thereof, if produced in the United States; or corresponding wording if produced in any other country outside Great Britain.

  • Blended Irish type whiskey (Irish type whiskey- a blend) is a mixture made outside Great Britain or the Irish Free State and composed of-
    (1) A mixture of distilled spirits distilled in pot stills at not more than 171 proof, from a fermented mash of small cereal grains, of which not less than 50% is dried malted barley and unmalted barley, wheat, oats, or rye grains, whether or not such proof is subsequently reduced prior to bottling to not less than 80 proof, or

(2) A mixture consisting of not less than 20% by volume of 100 proof malt whiskey or whiskeys distilled in pot stills at approximately 171 proof, from a fermented mash of dried malted barley, whether or not such proof is subsequently reduced prior to bottling to not less than 80 proof.
In Lieu of including the word “Type”, the designation may include the word “American” at the beginning thereof, if produced in the United States; or corresponding wording if produced in any other country outside Great Britain.

(3) Not more than 80% by volume of whiskey distilled at more than 180 proof and less than 190 proof, whether or not such proof is subsequently reduced prior to bottling to not less than 80 proof.

In Lieu of including the word “Type”, the designation may include the word “American” at the beginning thereof, if produced in the United States; or corresponding wording if produced in any other country outside Great Britain or the Irish Free State.