Mexico’s Secretariat of the Economy (SE) has sanctioned and fined the Mezcal Regulatory Council (CRM) for “deceptive, abusive” practices over the past three years. In two strongly worded June 30 rulings (oficios), the Director General de Normas painted a damning picture of the CRM’s behavior since 2017, and imposed total fines of over one million pesos ($45,000 USD). The rebukes conclude with a stern warning that repeated instances of the violations could result in the SE revoking the CRM’s mandate to certify mezcal.Continue reading
This post is the first in an ongoing series focusing on Mexico’s Denominations of Origin.
Denominations of Origin (DOs) are designations intended to identify and grant special protections to regionally-specific products and the people that make them. In Mexico, DOs must have a Norma Oficial Mexicana (NOM – a set of regulations) and a regulatory body established by the federal government. Research (especially that of Sarah Bowen and Ana Valenzuela) overwhelmingly indicates that the DOs, NOMs, and regulatory bodies of Mexico have failed to protect the people and cultures of these regions. Critics of Mexico’s DOs argue that they function more as standard business or trade associations – emphasizing volume, market share, and profits over the protection of the well-being of traditional producers.
I’ll be exploring these issues in blogposts over the next few months. I want to begin with the state of Jalisco, because I believe its DOs have a lot to teach us about where agave spirits in general are headed.
The state of Jalisco is home to Mexico oldest and most “successful” DO: tequila (declared in 1974). It is also home to Mexico’s newest DO: raicilla. And while Jalisco boasts one of the oldest of all mezcal traditions, its agave distillates are excluded from the DO for mezcal. These factors make Jalisco and its spirits a fascinating arena for discussion of DOs and their efficacy.
Jalisco is also important to Mexican national identity and history, boasts some the highest concentration of agave diversity in the country, and contains some of the oldest known sites of distillation in all of Mesoamerica. If there was pre-Conquest distillation, it was happening in what is now Jalisco. In any case, by the end of the 17th century, distillation was relatively widespread in Jalisco – in both Arabic-style alembics and Asiatic internal-condensation stills.
Over the centuries, regional distilling traditions evolved and diverged from one another to varying degrees. What is now called the tequila tradition can be traced back to the hacienda system of the eighteenth century, not only in Jalisco but throughout New Galicia – modern day Zacatecas, Guanajuato, Aguascalientes, and neighboring San Luís Potosí.
It wasn’t until the 1930s that tequila was officially called such, and between then and the 1970s, the spirit gradually cemented the wall between itself and other regional mezcales.
Future blogposts will address tequila and various regional mezcales of Jalisco. Here, we will focus on raicilla and its embryonic Denomination of Origin.
Raicilla refers to certain regional mezcales of western Jalisco. There are two primary producing regions: the mountains of the Sierra Occidental, and the coastal foothills in the municipality of Cabo Corrientes. The word “raicilla” was simply a linguistic innovation used to avoid taxes on vino mezcal centuries ago. The name is one of the only things these two regions’ spirits have in common. They are made from distinct agaves, and in fairly different processes. I will admit to being far better versed in the coastal than the sierra tradition. [See Experience Agave’s “raicilla basics” for more information.]
In 2000, the Raicilla Promotional Council of Mexico (CMPR) was formed by a number of raicilleros from both regions. That same year, the CMPR was granted a “marca colectiva” (collective trademark or brand) for the term raicilla, meaning that only members of the CMPR, adhering to its rules, could legally produce raicilla. The CMPR’s members elect their leadership, and the current (2018-2020) administration, working with various government agencies, officially declared the DO for raicilla in June 2019. The Norm that will govern the raicilla DO is currently being drafted, and the DO’s regulatory body has yet to be officially formed.
There are certainly positive aspects of a raicilla DO, and there are no doubt producers and brands who will benefit from it. Many academics and some raicilla brands and bottlers, however, have been critical of both the declaration itself and the process leading up it. Even the most ardent of these critics don’t object to a DO per se, however. Rather, they claim the process has been exclusionary, is being rushed, lacks academic grounding, and contains fatal flaws. These shortcomings, according to critics, seem designed to marginalize the most traditional producers and open the category up to domination by large commercial interests from outside of the region’s tradition.
In March 2019, the CMPR and proponents of the DO met with their critics and raicilleros from both regions at a National Forum on the Raicilla DO in Puerto Vallarta, Jalisco. I attended that meeting along with 60-70 others, took extensive notes, and have conducted follow-up interviews with various attendees. They have raised a number of concerns.
There’s a real risk that this DO, like those of the tequila and mezcal, will have no provisions for protecting natural, cultural, and human resources. There is already concern – and claims – that trees are being felled and land cleared for mass agave planting. The agaves used for raicilla exist in dynamic ecosystems where they, trees, wildlife, and the soil exist in a balance. This balance would easily be destroyed by intensive tequila-style monoculture.
The lack of concern for the environment in the DO declaration is nowhere clearer than in its inclusion of the threatened A. valenciana. This mountain agave isn’t currently used by anyone to make spirits, and at the national forum, no one could recall anyone ever having done so. So why is it included? The declaration specifically includes the valenciana, the various species that are traditionally used for raicilla, and “other” agaves, excluding only the tequilana Weber. If the DO is supposed to protect tradition, culture, and legacy, why allow for the use of “other” agaves that don’t currently exist in the territory and that have not historically formed part of the raicilla tradition?
I think we foreign aficionados tend to focus a bit too much on production techniques. Mallet crushing, Filipino distillation, and the like tend to get our attention (and open our wallets), sometimes at the expense of asking who is making the juice, who is profiting, and whose bodies and resources may be used up in the process. The Declaration, following the revised mezcal Norm, establishes three categories, including “artesanal” and “ancestral tradition.” These categories would be defined entirely by production methods, again as in the mezcal Norm. When technique is prioritized over culture and tradition, the category is vulnerable to usurpation and exploitation.One producer at the Forum pointed out that if these categories are defined simply by production methods, there is nothing to stop large companies from setting up massive distilleries employing “ancestral” methods (such as Filipino stills) and taking over that category commercially. (This is to an extent already happening in Oaxaca with powerful players – who for years denigrated clay pot distillation – now offering “ancestral,” clay-pot distilled mezcal in large volumes.)
Words like “traditional” and “ancestral” mean nothing if that designation does not include and protect the very families who have maintained the traditions of their ancestors for centuries, only to be cast aside now that there is money to be made in raicilla.
Both sides at the Forum expressed some support for a requirement that this category be the exclusive domain of producers with a demonstrated, pre-DO legacy of such production. Otherwise, we should expect a slew of exaggerated and invented histories from new brands, as is widespread in mezcal and tequila.
When the mezcal Norm was revised in 2016, it protected use of the autoclave (a stainless steel pressure cooker), under the argument that there were industrial producers already included in the mezcal category, and it would be unfair to toss them out.
The raicilla Declaration allows for cooking with autoclaves, despite the fact that not a single producer currently uses this industrial method. Mountain raicilleros generally cook their agave in above-ground clay ovens, while on the coast, cooking is predominantly in earthen pits.
It’s not just the inclusion of the autoclave that has many worried that the coming Norm will open the door for large spirits brands to enter (and ultimately dominate) the raicilla category. The DO itself includes not just villages where raicilla has traditionally been produced but the city of Puerto Vallarta and the resort-laden Bahía de Banderas. Either would be attractive locations for an industrial raicilla distillery, with easy access to both shipping and tourist markets.
Financial and technical support
Producing a legit DO product implies costs – not only to comply with health and safety standards but also to pay various taxes and fees to the regulatory body itself. Such expense can be prohibitive to small producers.
As the two sides were arguing back and forth at the Forum, the current CMPR board and their lawyer made a lot of promises that, so far, are not in writing. One was for financial and technical support for small, traditional producers. Everything from land, to agave, to the IEPS tax on alcoholic beverages carry price tags higher than most traditional procures can afford. Ideas that were floated (from both sides) included grants and loans, technical assistance on the agricultural front, a progressive fee structure in which poorer producers are subsidized by the better off, and having raicilla classified as a handicraft to avoid Mexico’s crippling 53% IEPS tax.
If some such measures are not taken, most of the smallest and most traditional producers will not be able to benefit from a raicilla DO.
While both the sierra and the coast are economically marginal, there is a clear difference in social class between the majority of producers in each region. Sierra producers are more likely to own land, have other businesses or income sources, already be connected to a brand or markets in general, and are more likely to own their own vehicles.
The rivalry and mistrust between the regions expresses itself clearly around the issue of the geographical location of meetings. They tend to happen in Mascota, which is a 3.5 hour drive from Cabo Corrientes, if one is lucky enough to have a vehicle. This geographical separation and the underlying class issues argue for, at the very least, meeting in the middle in Puerto Vallarta, if not for two distinct DOs for the sierra and the coast.
There is also a tacit assumption that the current leadership of the CMPR will become the regulatory body. But given the factional fighting within the raicilla community, that would be a mistake. The regulatory body should consist of producers from both regions, biologists, ecologists, and brand owners with real skin in the game.
Most of the raicilla producers at the forum (and all of those from the coast) expressed a certain fatalistic resignation about the Denomination of Origin for raicilla. They spoke of previous failed projects, hijacked by outside interests and politicians, and it was clear they don’t feel that they are in the driver’s seat when it comes to the DO. It is, of course, tragically contrary to the entire DO concept for traditional producers to feel excluded. At the same time, it speaks to a resilience and a commitment to tradition that transcends labels and jurisdictions. As one producer from San Sebastián del Oeste put it: “I don’t know much about this. But I know how to make raicilla. For me, it’s all good. If the DO comes, it’s good. And if it doesn’t – fine. I’m going to keep working.”
Keep an eye on this space for updates on the Norm and formation of raicilla’s regulatory body.