On the evening of 27 March 2024, federal authorities conducted a raid on a home in central Tlaquepaque, a city bordering Guadalajara to the south in Mexico’s Jalisco region, that was suspected to be an illegal tequila factory.
According to the Attorney General’s Office, authorities were executing a search warrant originating from a complaint filed by the Tequila Regulatory Council (CRT), representatives of which were present at the scene. No arrests were reported but equipment associated with distilling was seized from the property.
This scene reads as another successful raid on another Jalisco bootlegging facility until the identity of homeowners was revealed as Grover and Scarlet Sanschagrin, the husband-and-wife co-founders of the online tequila database and educational platform Tequila Matchmaker.
The Sanschagrins haven’t spoken publicly or made any accusations about the motives behind the raid, but commentators within the category were quick to draw links to the couple’s ongoing war of words with the CRT surrounding Additive-Free Alliance, an initiative they launched in 2020 which invited brands to be certified as being free of additives.
“We saw consumers that were being confused about tequila profiles – vanilla cake batter is not a naturally occurring flavour, that's an additive – but when people were getting used to that profile and then moving on to small-batch, artisanal, family-made tequilas, and thinking they’re harsh and that something’s wrong with them, that's when we started to think we need to do something,” explains Grover from the couple’s new home in Florida in the United States.
“In the beginning, we required the collection of samples from throughout the process, and the full disclosure of every part of their production. In some places, tequila manufacturers think that their process is a proprietary secret, even though it might not be, and so for them to divulge this kind of information to us could be a big ask.”
The programme has since evolved to lab testing of bottles once they have been made available for retail. The initiative has been welcomed among the more bookish end of the agave spirit consumer-base, with the 111 member brands heralded as bastions of authenticity and integrity in artisanal tequila production. But a surprising realisation from the initiative is how confusion exists even among brand owners.
“It happens a lot where a brand thinks they are additive free and they’re not. Distilleries are not being transparent with their clients. If you're a contract brand and you say you want something additive free, they can tell you for sure, it’s additive free, because they know that nobody’s testing for it,” says Grover. “Then they send us their products to join the programme, and we send them off to testing. It ends up creating an awkward situation for us and for the brand and for the distillery. At the moment, we have an 80% failure rate but I think the industry is now learning that testing is possible, and what we can test for and that they need to clean up their act.”
The CRT has been less than keen on the programme. In January it denounced the initiative, with a spokesperson for the organisation saying: “We consider that any scheme offered in the market to ‘certify’, ‘verify’ or ‘confirm’ in any language that a certain trademark is ‘additives free’ represents an act contrary to good customs and practices and induces error or confusion to the tequila consumer.”
The CRT itself then announced its own certification, the Naturaleza Libre de Aditivos Producto Certificado, an initiative that by all accounts appears at present to be mothballed.
“I think their point is that the regulations allow for some additive content and so why call it out,” says Scarlet. “What’s confusing is that they allow additives that don’t have to be listed. There is no indication that they will have a tequila programme and the last thing we heard was a member of our team called their press office and asked them about it and were told that if they launch an additive-free programme in the future, it will still permit abocantes.”
Abocantes refer to the four additives that are permitted to account for up to 1% of tequila by volume without being disclosed on the label according to the norma, the legal definition of tequila. Herein lies the disagreement. Those who side with the Additive-Free Alliance believe that to be called an additive-free tequila it should be made only from agave, water and yeast.
Implementation issues
The norma allows for 100% agave tequila to include those four abocantes; glycerin, caramel colouring, oak extract and sugar-based syrups called jarabes – additives that are often present in manufacturing across the spirits world, but it’s in their implementation where the disputes have arisen.
“In tequila, there’s a lot of passionate producers who have seen the profile of tequila change quite considerably, and within the category of tequila, these additives aren’t being used quite as subtly as they are in some of the classic spirits,” says Tom Bartram, agave spirits expert and North & Midlands sales manager for Speciality Brands.
“One of the main things is just how artificial some of these sugar-based spirits taste, the loophole of it being sugar-based syrups is how they get around adding intense vanilla extract among other things. One of the first times I judged a spirits competition, I was assigned spiced and flavoured rums and for the next three days I was brushing my teeth. Now when I judge the tequila category, I often feel the same artificial taste. What scares me is that it will reach a point where tequila is classified as an agave-based spirit that’s flavoured with all sorts of things. Some producers who are proudly producing some very good tequila without additives see it as potentially catastrophic for the category if it’s allowed to continue in the same direction as the last couple of decades.
“It’s difficult for anyone to speak out. People who’ve gone up against the big powers and tequila have been shot in the street before. Cognac is permitted to add sugar, caramel colouring and oak extract – you don’t see anyone being gunned down in Jarnac.”
He’s not kidding. While not strictly about additives, protests against declines in production standards in tequila have reportedly resulted in at least one fatality. Back in the 1990s, disease swept through many of Mexico’s agave fields causing a massive shortage and the price of tequila to skyrocket. The result was the birth of the mixto. For the first time, producers were using sugars alongside cooked blue weber agave in the fermentation of their tequilas, a great existential tragedy for tequila artisans, and many took to the streets of Jalisco in protest. According to Rex Dalton writing in Nature in 2005: “At least one vocal producer, who spoke out against reducing the tequila standards, was assassinated during public demonstrations.”
Market swing
But while the transition to mixto was seen as the opening of Pandora’s box at the time, the market did eventually swing back towards 100% agave tequila. According to CRT statistics in 1997, 113.5 million litres of mixto were produced against 43 million litres of 100% agave tequila, but every year since the opposite has happened. At the category’s peak in 2022, 470.4 million litres of 100% agave tequila were produced against 181 million litres of mixto.
“I think the transition from mixto to 100% agave is a good parallel for what’s happening now with additive-free tequila” says Mike Dolan, co-founder of Mijenta, a member brand of the Additive-Free Alliance. “When 100% agave tequila started gaining traction in the early 2000s, it turned the page on mixtos almost overnight. What happened from a consumer perspective was that it essentially redefined the concept of quality within the category.
“Mixtos were what college kids were doing shots of, but 100% agave tequila you could sip and appreciate in a way that you couldn’t with a mixto. It was more elevated, more sophisticated, more refined. And the same thing is happening now – the concept of quality within tequila has been redefined again, and this time it’s additive-free replacing tequilas that use artificial sweeteners and flavourings. And the data bears this out. Our own recent review of Nielsen data showed additive-free brands growing at 10 or 20 times the rate of brands that use additives, depending on how you segment the price bands, while many of the big brands that use additives are both cutting price and losing market share.”
But change could be on the horizon. At the end of May, a new certification body, Certificadora Royalty, was accredited to inspect and certify tequilas, and on approval by the Mexican Ministry of Economy, would disrupt the CRT monopoly. It’s too early to say what kind of impact a competing regulatory body might have, but if it can gain the trust of additive-free producers, it could have a small but vocal groundswell of support.
“It should be the CRT who verifies [additive-free production], but they haven't been able to,” says Sergio Mendoza, co-founder of Don Fulano tequila. “The consumer, not only of tequila but of all produce, wants to know what they are consuming. Transparency is key moving forward and if CRT doesn’t want to do it for tequila, there will be someone else trying to. The ideal scenario would be that there is one regulating body that does a great job and everybody is happy. However, given the circumstances, it might be good to have alternatives.”
A spokesperson from Certificadora Royalty told Drinks International it will wait for that approval before making any public statements.
But while a public outlining of aims hasn’t yet happened, the Sanschagrins remain cautiously optimistic.
“I know the head guy behind it [tequila maker Fernando Luévano],” says Grover. “He's always been very much interested in transparency, disclosure and education, and I know that he has for years been frustrated with the CRT for their lack of transparency. I think he sees the role of a regulator not just to be a controller, but someone who can help the category along with education and open information, so I think there’s a chance that they could go in that direction, and if so, that would be a really great thing for the industry.
“With a single regulator, brands are afraid to speak out publicly as it's very risky to say anything negative. But privately, in the years I’ve been in and out of distilleries, pretty much the main topic of discussion has been complaining and how they favour the big brands. If this new regulator can earn trust from these small brands, many of them will switch.”
Whether a new regulator will even have an opinion on the additive-free debate or make any impact whatsoever on the category is guesswork at this point. But right now, as more drinkers than ever before are being introduced to tequila, there’s a battle raging for what it is that they’re being introduced to, and that’s important.
