“Even with tariffs reduced, the products still get sampled and tested,” Ian Duddy, international director of the Scotch Whisky Association, said this week while visiting India with a UK government trade delegation. Three months after the UK–India trade agreement cut India’s customs duty on Scotch from 150% to 75%, the industry’s complaint has moved from the tariff to the laboratory.
The deal that took effect on July 15 changed the price of entry, not the rules of entry. Imported Scotch must still clear India’s food-safety regime, and some of it now faces customs investigators, who last week searched the offices of Diageo’s Indian business over whether bulk imports qualified for the lower duty at all. Both checks have the biggest impact on bulk whisky, the unglamorous trade that made up roughly four-fifths of the Scotch shipped to India by pure alcohol volume in 2024 and that disappears into Indian-market blends.
The Food Safety Tests the India Trade Deal Leaves in Place
India’s Food Safety and Standards Authority (FSSAI) clears imported food and drink through an online system linked to the customs portal. Its risk management system selects consignments for sampling and laboratory testing according to risk profiles, alongside document checks and visual inspection, under import regulations dating from 2017. FSSAI publishes no figures on how often whisky is sampled or how long tests take.
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READ THE STORYThe SWA wants Scotch treated as low risk, arguing that India should reconsider sampling and testing because the UK places no equivalent condition on Indian spirits sold in Britain. “Obviously, alcohol and all food products need to be regulated. We’re not arguing against that,” Duddy said, adding that the association does not believe Scotch “needs to be regularly sampled and tested.”
The SWA made the same complaint a year ago, telling a House of Lords committee that the industry faced “unnecessary and costly conformity testing and sampling requirements” at federal level in India. The agreement’s customs chapter commits both countries to endeavor to release goods within 48 hours, but only where paperwork is complete, no physical inspection is required and all regulatory checks are finished. It adds that nothing obliges a country to release goods that have not met its regulatory requirements, and a separate chapter preserves each side’s food-safety rules.
The text does give the industry a standard to argue over, because each country must run risk management that concentrates inspection on high-risk consignments, speeds low-risk ones and avoids “arbitrary or unjustifiable discrimination.” Without published hold rates for Scotch since July, there is no public evidence that India is falling short of that test.
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Why Bulk Scotch Carries the Weight
India took 53.7 million liters of pure alcohol (MLPA) of Scotch in 2024, regaining its place as the industry’s largest market by volume. Bulk malt accounted for 22.2 MLPA, bulk blend for 16.2 MLPA and bulk grain for 4.8 MLPA, against 9.3 MLPA of bottled blends and 1.2 MLPA of single malt. That puts bulk at about 80% of the total, and India alone absorbed more than 70% of all the bulk malt Scotland exported that year.
The trade kept growing in 2025, when the SWA put shipments to India at the equivalent of 220 million 70cl bottles, up 15%, worth £286 million. That figure is a standardized measure of volume, not a count of bottles crossing the border, because most of the liquid travels in containers and is blended and bottled in India.
This is the whisky inside Pernod Ricard’s Royal Stag and Blenders Pride and Diageo’s McDowell’s, which mix imported Scotch with locally distilled spirit, and Pernod and Diageo are the two companies now answering questions from customs investigators.
The Bulk Scotch Classification Question
India’s Directorate of Revenue Intelligence searched offices of United Spirits, Diageo’s Indian business, at several locations on October 16, in what the company called an “industry-wide exercise.” Pernod Ricard says it is cooperating with the same agency, and people familiar with the matter say inspectors questioned executives at its headquarters near New Delhi about Scotch imports.
The inquiry is understood to concern bulk Scotch concentrates, the Scotch shipped in containers to be blended into Indian brands, with inspectors arguing that the treaty’s duty relief does not extend to them. Neither the directorate nor the companies have said what separates a concentrate from the bulk malt and grain counted in export statistics, or which rate of duty the investigators believe should apply instead. Diageo says it has always complied with local laws, Pernod says it is committed to answering the authorities’ questions, and no finding or penalty has been announced.
The industry had understood bulk to be covered, and in its evidence to the Lords last October the SWA said the tariff cuts “will apply to both bottled and bulk exports, with no minimum import price threshold.” Whether a particular concentrate counts as Scotch whisky under the agreement’s tariff lines is a question of customs classification, and the answer will decide how much of the headline saving reaches the bulk trade.
What the India Trade Deal Changes, and What It Doesn’t
India’s duty on Scotch is scheduled to fall in stages to 40% by the tenth year of the agreement. For decades imported Scotch carried a 150% basic customs duty, with additional federal levies once pushing the total burden far higher, and European Union talks that might have eased it began in 2007 and stalled in 2013.
Indian states set their own excise rates, prices and route-to-market rules, and the treaty leaves those untouched, so a halved customs duty does not mean a halved shelf price.
For drinkers, little changes until the savings survive state taxes and distributors’ margins. Whether FSSAI eases its risk profile for whisky, and whether the revenue inquiry ends in formal demands, matters more to distillers selling in bulk. For them, the outcome now rests less with trade negotiators than with two Indian agencies: a food regulator deciding how risky Scotch is, and a customs directorate deciding what counts as Scotch in the first place.
