Okay, I had written an earlier answer but it is not complete so I wiped it and here is the final answer. Division 2 of the Food and Drug Regulations, enacted under the Canadian Food and Drugs Act, lays down standards for Canadian whisky and rye whisky (considered synonymous). As I said earlier, they include that the whisky must be aged in "small wood" for at least "three years". Also it must have the aroma and taste characteristic of Canadian whisky (from here on I won't quote textually but take it from me this is what it says). The regs also say caramel or flavouring can be added. Flavouring is defined in the these same regulations as any domestic or imported spirit or wine. Spirit is not defined. It also says that the Excise Act defines further what amount of flavouring can be added. In the Distillery Regulations, enacted under the Excise Act, it states, (here I will quote in part), that you may add flavouring to spirits (including whisky) and are not required to indicate on the label the time for which the addition was aged if the flavouring, i.e., the "additional domestic or imported spirits or wine", "does not exceed 9.090% of the total quantity of ethyl alcohol in the final product".
In other words, you can add more than that percentage of ethyl alcohol but if you do you lose the benefit of claiming on the label the age of the whisky as it was before the addition was made. So in practice distillers hew to the 9.090% rule because they will want, say a 6 year old whisky to which such flavouring is added still to state 6 years old on the label.
Based on my knowledge of whisky blending, which extends to reading a number of early manuals on the subject, e.g. Joseph Fleischman's book from 1885, fruit-based additives were macerated in grain neutral spirit. Fleischman specifically advises, for each fruit preparation for which he gives a recipe (made from varying combinations of prunes, currants, raisins, peaches, etc.) to prepare the extracts in "spirit" (i.e. GNS), and fairly large quantities, too. Likely this was done to preserve the fruit extract or possibly to better leach out the fruity taste, since there is an old expression, "fruits drink alcohol" (guys, I've been studying this stuff for a long time, maybe too long
), i.e., the alcohol goes in, the fruit taste goes out into solution. So, to allow for that traditional way fruit-based whisky additives are made, I believe the regulation was, a long time ago, crafted to include this reference to spirit.
However as things stand now, clearly only "wine" or "spirits" can be added. I note later in the Distillery Regulation "wine" is defined to mean amongst other requirements something fermented from "grapes". Fruit wines are allowed but must (in effect) be called "fruit wine", "apple wine", etc. So it seems clear only true wine such as dry red wine or (more likely in practice) sherry or port (the wine part of the regulation seems to allow addition of spirits to wine, which is what port and sherry are) can be added to whisky as "wine". I don't think "prune wine", today at any rate, qualifies as a flavouring if I read these laws correctly. Probably at one time prune wine could be added but I suspect the regulations were tightened over the years so that now only "wine" (grape-derived) or "spirit" (any kind) can be added to whisky and other spirits within the bounds mentioned earlier above - and caramel, as stated earlier above. But not say cinnamon or licoriec, probably in that case you would have to say on the label that the product is flavoured specifically in this way and a different part of the regulation would apply. Probably this is the situation regarding the spiced and other-flavoured whiskies we have in this country, i.e., they just don't say "whisky" on the label but (I surmise) have to say more to explain to the consumer how they are confected.
Do the regs therefore mean that manufacturers or dealers can cut aged Canadian whisky with only GNS and still call it, say 6 year old Candian whisky if the whisky being added to was that age and provided the limit of 9.090 % ethyl alcohol added is not infringed? Clearly yes, so you are right Mick. Under our law, the addition is deemed to be aged for the requisite period as long as the whisky to which it is added is, so no issue arises about indicating the addition here on labels. Maybe in the States that is different and possibly as I said earlier even more than 9.090% ethyl alcohol can be added from this source (GNS) to Canadian whisky and still allow it to be sold as Canadian whisky in the U.S.; if so that is a result allowed by U.S. law for U.S. purposes.
But I tip my hat to your knowledge, Mick, and to you Chuck who spotted in Jackson's 1980's World Guide To Whisky that statement about the possibility of adding GNS to Canadian whisky. One thing people here know about me or should know is I always want to learn more, and I always welcome suggestions how I can expand my knowledge. We are here to educate each other and thus expand the public knowledge base in the area.