What can & can’t be done right now while the TTB is shut down.
Posted on 2013-10-02 by Ann Reynolds

shutdownThe TTB is shutdown. Those were the words those of us in the compliance world of wine woke up to yesterday. It still sounds so surreal to me. So what exactly does it mean? For wineries? For those wanting to start their new wine business?

Here’s a brief summation of what “can” and what “can’t” currently be done right now depending on which category you fall into as well as my suggestions for what else to be doing right now to have ready for when the TTB comes back to life.

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“I have known and worked with Ann for twelve years and her experience in production and consequently positions in wine/cellar tracking and compliance have always been innovative, timely and accurate. As the Quality Control Manager and lab director for Sterling Vineyards, Ann’s skills and work ethic have made the responsibilities and logistics of my position run smoothly and efficiently.”

Julianna Beckmann Gosling
Assistant Winemaker, Rob Lawson Consulting
What do the proposed Paso Robles AVAs mean for your weigh tags right now?
Posted on 2013-09-26 by Ann Reynolds

AVA

I see that 11 new petitions have recently been submitted to the TTB for new AVAs all within the current Paso Robles AVA. For one, that’s a lot of slicing and dicing all at once! And of course there has already been plenty of history to the quest to create several more sub-AVAs within the sizeable piece of land that the parent AVA Paso Robles already is. (5th largest in California)

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Wineries: No cross outs on your weigh tags!
Posted on 2013-09-17 by Ann Reynolds

It’s game on for crush 2013. I now regularly see trucks carrying those familiar white plastic bins on the roads here in Napa. Once the grapes start rolling in things heat up pretty fast. (No fermentation-related pun intended) Things can also quickly become rather chaotic when it comes to harvest related recordkeeping. Specifically your weigh tags. If you are someone who fills out weigh tags- I’ve got a warning reminder for you: one thing the county and the state do NOT want to see on your weigh tags: numbers that are crossed out. Those numbers would of course be your weights, the gross, tare and net that are filled out on a weigh tag. Continue reading





What does wine production really mean?
Posted on 2013-09-09 by Ann Reynolds

napa-county-logo-150x150

I’ve recently read some articles about random audits here in Napa county conducted by the planning office. These random audits occur annually on 5% of Napa’s wineries which hold use permits with the county planning office. One of the key items they are looking at during these audits is a winery’s production gallons. The term production gets tossed around a lot in the wine business. It means different things to the different people and different agencies connceted to it, and in my world of compliance it has very specific definitions given to it by government agencies such as the county planning office in this case. It is also a specifically defined term used by the Alcohol Tobacco Tax & Trade Bureau (TTB). Do you know the difference in definition between those two agencies and how it can impact your winery?

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Harvest (training) on Sale!
Posted on 2013-08-28 by Ann Reynolds

on-saleYep- it is game on for harvest 2013 from the sights and stories around here in Napa County. Mostly the “early” varietals so far, your lower alcohol wines. I’ve been hearing from several folks with random crush related questions around their compliance. Nothing like waiting til the last minute! If you haven’t seen it already- take a look at my last post with some suggestions for preparing your harvest compliance tasks.   The questions I’m getting are mostly around the topic of weigh tags. Those (regulated) documents used for tracking (& buying & selling) loads of grapes. Do you know whether your weigh tags meet federal, state & county requirements? 

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Harvest 2013 is Here! Is Your Compliance Ready?
Posted on 2013-07-25 by Ann Reynolds

Another annual cycle is once again upon us in the wine business: harvest. AKA “crush”. The predictions that have been floating around out in web postings for the past month state that this will be an early and big year for grapes here in Northern California. Early and big. Two words that when used in combination to describe the grape harvest tend to leave winery staff cringing. The unpredictable nature of the grape harvest definitely adds a level of excitement (or frustration) for those who have to deal with the tracking area of winery records.  This means you if you are a weighmaster or manage data entry of harvest work orders and keep track of your wines as they become “produced”. If this sounds like you do you know if all your records are ready? Do you know how you can tell?

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Woops Wineries……….did you spill something?
Posted on 2013-06-13 by Ann Reynolds

I just recently read a story about a spill that happened at a winery where a tank holding 7,500 gallons of wine had a bolt break, causing the wine to spill out and head rapidly down the drain.

I’ve actually seen a few of these wine loss events happen over the years at different wineries and definitely the bulk of the activity happens frantically as the scene originally unfolds. Cellar crew scrambling madly to catch the wine spraying out from the tank and re-direct it into another one to minimize the overall loss as much as possible. A pretty incredible event to watch to see the crew spring into action and coordinate their efforts to manage the chaos as best as possible.

But what about afterwards? After the frenzy has died down, wine gallons have gone down the drain, and the rest have been relocated into other tanks/vessels? Do you know what details need to be sent to the TTB to inform them of the wine loss?

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Guess what Alternating Proprietors? You CAN take your COLAs with you!
Posted on 2013-06-05 by Ann Reynolds

Today’s blog post is for anyone who either is an Alternating Proprietor (AP) or is a site that hosts them & offers TTB label approval submission assistance. I just learned this newest TTB update twist last week that can save you some time when planning for your bottlings- by eliminating the need for the label approval step in that process. Here’s the scenario I’m talking about. One of the advantages as an AP is that since you are sharing the space of an already existing winery if you decide you need a change of scenery you can pick up and “move your winery” to another site that hosts AP’s. Now after you’ve made that move, how does it then impact your label approval activities?

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TTB Label Approvals……Make Sure to Plan Ahead!
Posted on 2013-05-01 by Ann Reynolds

Wineries beware! TTB label approval times are now back up to over 30 days!
Here is my post from 2 years ago w/info on how you can plan ahead for this necessary step in the process:

All wines that are bottled by wineries to be sold for consumption are required to have a federal label approval. The industry term for this is certificate of label approval, or COLA. Of the three alcoholic beverage categories (Beer, Wine and spirits) the number of applications for label approval received by the federal regulating agency, the TTB from the wine industry makes up over 80% of the total. Add to this scenario the current government budget issues which have resulted in staff cuts and retirements at the TTB and the end result is label approval processing time has gone up. Many in the industry had become accustomed to their label approval turn around time lasting about 10 working days. (This is for those using the TTB’s electronic filing system, COLAs Online) That time frame now has now gone up to 38 Days!

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5 Gallon Kegs, Label Approvals and You.
Posted on 2013-04-12 by Ann Reynolds

5 gallon kegs have become a popular way for wineries to get their product out into the marketplace, specifically the by-the-glass marketplace. I had a client contact me recently for assistance with a new label approval (COLA) for his upcoming bottling. I’ve filed these for him in the past but this year was the first time he’d decided to try out the 5 gallon keg route. He asked me if a label approval was required for them, and I honestly didn’t have an answer for him right away.

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