Under the UK-US and EU-US trade agreements concluded this summer, Irish whiskey originating from the EU now faces a 15% tariff in the US. In contrast, Irish whiskey distilled in Northern Ireland and Scotch whisky are UK-origin goods and attract a lower 10% tariff. Although the gap may appear small, it is already influencing producers, distributors, and consumers alike.

The disparity is most evident on the island of Ireland. Jameson, a well-known Irish whiskey brand, is distilled in County Cork and therefore of EU origin, attracting the full 15% tariff, on import into the US.

By contrast, Northern Irish producers such as Bushmills, benefit from the UK-US trade deal, facing only a 10% tariff. This has created a de facto tariff border within Ireland itself, complicating pricing and logistics for companies operating across both jurisdictions.

As increased tariffs push shelf prices higher, US consumers’ choices between Irish and Scottish products may be influenced, potentially impacting on sales of Irish whiskey. However, given the excellent reputation and renowned quality of both, consumers may accept the extra cost and continue as normal.

All Scotch whisky produced in Scotland, including brands such as Macallan, currently benefit from the 10% tariff. However, this still represents a notable hit to profits compared with the zero-tariff access enjoyed until earlier this year.

Consequently, Scotland is actively lobbying for further tariff relief. Scottish First Minister John Swinney recently visited Washington D.C. for talks with President Trump and US trade officials and was joined by representatives from the Scotch Whisky Association, arguing for a “zero-for-zero" deal.

This would eliminate tariffs on Scotch entering the US, while also removing tariffs on American Bourbon entering the UK. It should also be noted that US bourbon producers sell hundreds of millions of pounds of used barrels to whisky producers each year, so any reciprocal deal would be of mutual benefit. Swinney’s visit demonstrates the strategic importance of Scotch whisky to the Scottish economy and the urgency of securing a more favourable trade deal.

For businesses, the new tariff regime continues to present complex challenges. Pricing models, supply chain strategies and market positioning must all adapt. Some Irish producers may even consider relocating production to Northern Ireland to reduce tariff exposure. Scottish distillers, while currently enjoying a relative advantage, remain at risk of future policy changes and will continue to seek longer-term stability.

In this shifting environment, reviewing supply chains and carefully assessing customs rules of origin is vital. With US trade policy in flux and rapid changes possible, businesses must remain agile and prepared to adapt.

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