Tequila and Mezcal: Production and Classification Overview

Tequila and mezcal occupy a uniquely regulated space within the global spirits market, governed by Mexican federal standards that control everything from the agave species permitted to the geographic zones where production may legally occur. Both spirits are protected geographical indications recognized under Mexican law and acknowledged in international trade frameworks. Understanding the distinctions between them — and the classification tiers within each — is essential for importers, retailers, and consumers operating under United States federal labeling and import requirements. A broader introduction to the regulatory landscape governing these and other imported spirits is available at the Global Spirits Authority index.

Definition and Scope

Tequila is a distilled spirit produced exclusively from the blue agave plant (Agave tequilana Weber, blue variety) within a defined geographic zone that includes the state of Jalisco and portions of 4 other Mexican states: Guanajuato, Michoacán, Nayarit, and Tamaulipas. Mezcal draws from a broader set of agave species — over 30 are permitted under current standards — and its authorized production zone spans 9 Mexican states, including Oaxaca, Guerrero, Durango, San Luis Potosí, and Zacatecas, among others.

Both spirits are regulated by the Consejo Regulador del Tequila (CRT) and the Consejo Mexicano Regulador de la Calidad del Mezcal (COMERCAM, now operating as CONSEJO REGULADOR DEL MEZCAL — CRM), respectively. These bodies enforce compliance with the relevant Normas Oficiales Mexicanas (NOMs): NOM-006-SCFI-2012 governs tequila, and NOM-070-SCFI-2016 governs mezcal. Both NOMs are administered through Mexico's Secretaría de Economía.

In the United States, tequila and mezcal imports are regulated by the Alcohol and Tobacco Tax and Trade Bureau (TTB), which requires Certificate of Label Approval (COLA) for all spirits sold in interstate commerce. Importers must also comply with TTB's labeling standards for imported spirits and any applicable tariff schedules administered by U.S. Customs and Border Protection.

How It Works

Tequila Production Process

Tequila production follows a structured sequence defined by NOM-006-SCFI-2012:

• Agave harvesting — Blue agave plants are harvested at maturity, typically between 7 and 12 years of growth. The jimador removes the leaves to expose the piña, the starchy core.
• Cooking — Piñas are cooked in industrial autoclaves or traditional stone ovens (hornos) to convert complex carbohydrates into fermentable sugars.
• Extraction — Cooked agave is crushed mechanically (roller mills or a traditional tahona stone wheel) to extract juice, known as aguamiel.
• Fermentation — Extracted juice is fermented with cultivated or wild yeasts, typically over 24–96 hours. Fermentation vessels may be stainless steel, wood, or stone.
• Distillation — NOM-006 requires a minimum of 2 distillations, most commonly in pot stills or column stills. Final distillate must fall between 35% and 55% ABV (TTB, Beverage Alcohol Manual).
• Aging (if applicable) — The spirit is rested or matured based on its target classification tier.

Mezcal Production Process

Mezcal production under NOM-070-SCFI-2016 permits greater artisanal variability:

• Crushing may use a tahona, wooden mallets (mazo), or mechanical mills, depending on the production category.

Common Scenarios

Tequila Classification Tiers

NOM-006-SCFI-2012 establishes 5 formal age-based categories:

Category Minimum Rest/Age Container

Blanco (Silver) None required Stainless or neutral vessel

Joven (Gold) None (may be blended) Blanco + aged tequila or coloring

Reposado 2 months in oak Oak barrels or containers

Añejo 1 year minimum in oak Oak barrels ≤600 liters

Extra Añejo 3 years minimum in oak Oak barrels ≤600 liters

Additionally, tequila carries a critical commercial distinction: 100% agave versus mixto. Mixto tequila may derive up to 49% of its fermentable sugars from non-agave sources (typically cane sugar). Only tequilas produced from 100% Agave tequilana Weber blue variety may carry that designation on the label.

Mezcal Classification Categories

NOM-070-SCFI-2016 classifies mezcal across 3 production-method tiers and 3 age-based designations:

Production method categories: - Mezcal (industrial methods permitted) - Mezcal Artesanal (traditional tools; distillation in clay or copper stills) - Mezcal Ancestral (distillation exclusively in clay pots; most restrictive methods)

Age designations: - Joven — no wood aging - Reposado — minimum 2 months in wood - Añejo — minimum 12 months in wood

A sub-category designation of ensamble identifies mezcals distilled from 2 or more agave species simultaneously, while pechuga denotes a third distillation conducted with raw ingredients (meat, fruit, or grain) suspended in the still.

Decision Boundaries

The regulatory and commercial distinctions between tequila and mezcal rest on 4 principal axes:

1. Agave species — Tequila is locked to a single variety; mezcal permits over 30 species, including Agave espadín (the most commercially common), Agave tobalá, Agave tepextate, and Agave karwinskii.

2. Geographic origin — A spirit labeled tequila must originate within the 5-state CRT-certified zone. A spirit labeled mezcal must originate within the 9-state CRM-certified zone. Agave spirits produced outside both zones cannot legally carry either designation.

3. Production method — The pit-roasting of agave is legally specific to mezcal; tequila's NOM does not permit pit-roasting as a production method. This single difference drives the primary sensory distinction between the two categories.

4. Labeling and import compliance — In the United States, all spirits must comply with TTB regulations under 27 CFR Part 5. Tequila must be labeled with its NOM number (a 3–4 digit distillery identifier assigned by the CRT), enabling traceability to the registered production facility. Mezcal labels must reflect the CRM-assigned certification lot number. The regulatory context for global spirits provides a detailed treatment of how these Mexican standards interact with U.S. federal import and labeling law.

Spirits that use agave but fail to qualify for either designation — due to geographic origin, species, or process deviations — must be labeled generically as agave spirits under TTB classification rules, without reference to tequila or mezcal.

References

• Consejo Regulador del Tequila (CRT)
• Consejo Mexicano Regulador de la Calidad del Mezcal (COMERCAM, now operating as CONSEJO REGULADOR DEL MEZCAL — CRM)
• Alcohol and Tobacco Tax and Trade Bureau (TTB)
• TTB, Beverage Alcohol Manual
• 27 CFR Part 5