Purchase bulk wine? Here’s how to document it to meet TTB & CA requirements
Posted on 2016-05-25 by Ann Reynolds

Bulk wine. That’s the wine industry term for wine that isn’t in a bottle yet. Instead it is sitting at a permitted winery site in some sort of container, be that a stainless steel tank, a barrel, a drum or a keg or these days perhaps a cement “egg”. Wineries will decide to sell some of their bulk wine that they don’t plan to use in their bottled blends. They’ll put it on the bulk wine market through a wine broker. Every day on the Wine Business website they list a link to the “Recent sales of grapes and bulk wine“.

When wineries purchase wine from the bulk wine market there is a specific document that comes with the delivery of that wine, called a bill of lading or a transfer in bond record to the TTB. That document is required to have specific details on it to satisfy TTB regulation requirements. Here in California there is also a state requirement for documenting the sale which is a weighmaster certificate. 

Wineries on both ends of the sales transaction have responsibility for ensuring that both of these regulated documents are completed correctly. What exactly are the details that must be listed on each of these documents?

For the TTB they have a specific set of items that are required to be listed on any “transfer in bond” record which is what they call a bill of lading for shipping wine between wineries. Here are a few of the items they require:

  • The name, address & registry number of the proprietor and consignee 
  • Shipping date
  • Alcohol content OR tax class
  • volume shipped in gallons or liters
  • The varietal, vintage, appellation or any other information that may be stated on the label

To meet the requirements for the weighmaster certificate, which are regulated by the California Department of Food & Agriculture this document must contain 13 items, a sample of which can be seen here: Weighmaster certificate requirements

The reason for the weighmaster certificate requirement here in California is that a bulk wine sale is just that, a sales transaction and the completion of a weighmaster certificate means that the full set of weights for a load of bulk wine were completed by a site with a weighmaster license. Those weights will then be used to convert them into the gallons delivered which will be the number used to base the payment of the sales transaction between the wineries. 

In working with wineries I regularly see completed bills of lading for bulk wine movements. These are both bills of lading they received from another winery or ones that they completed themselves. Now perhaps it is just my years of winery compliance background but the errors I regularly see on these completed forms is my business’ world version of nails on a chalkboard. 

Some of the most common issues I see on these (translation: they were filled out incorrectly) are:

  • The registry number requirement. Wineries- your registry number is the one that starts with either BW or BWN (!!) It is NOT the one that starts with your state’s abbreviation! 
  • The name and address of the winery the wine is sent to. Sounds simple enough right? Time and time again I see the wrong winery name listed in the receiving winery section. What is required to be listed there is the actual name that is listed on that winery’s TTB permit. The address then also of course needs to be the actual physical address of the winery site, not the “office” address which these days is often another site.
  • The vintage, varietal and appellation summary. Some common mistakes I see here are they are either illegible or incomplete.  Many bills of lading are still hand written thus the common illegible issue. Plain and simple they are chicken scratch. In my years at wineries whenever I was on the receiving end of a BOL that I couldn’t read I simply called the sending winery and requested that they send me a clearly written revised one. (their responsibility)  As far as the wine blend summaries being incomplete the issue I’ll see here is that they won’t match up with the blend summary originally provided by the wine broker when the purchasing winery sampled it. For example a wine broker’s blend summary listed a wine blend as 80% Cabernet Sauvignon & 20% Petite Sirah, 90% Napa Valley & 10% Lake County, & 100% 2014. In contrast to this the BOL sent with the shipment will list the varietal and vintage details accurately but the appellation will list 100% Napa County. The issue with this is that it will directly impact what the purchasing winery will qualify to list on the label that this purchased wine becomes a part of. It would NOT qualify to list Napa Valley as the appellation as it’s “source document” (what the TTB calls the BOL in these situations) does not document it as Napa Valley.  Here again the receiving winery needs to call the sending winery and request that they send them a revised BOL with the full accurate blend details.

If you’re reading this and have any follow up questions for your winery related to properly documenting this common activity of purchasing bulk wine feel free to respond to this post or sign up for one of my “Compliance Check in Calls”





Being smart about starting a new wine business
Posted on 2016-05-20 by Ann Reynolds

I came across this article recently about the “top 10” mistakes that US wineries make in the US market. It was focused on wine importers however I found it to cover several very relevant point for any new wine business.

I have conversations every week with people who are in the beginning stages of starting their own wine business. They are very excited about the prospect of having their own wine in the bottle to show off with the label they’ve been designing in their mind. While I generally enjoy listening to their enthusiasm afterwards I’ll also make sure to include in these early conversations the details that are important for them to plan for if their wine business is to be a success in the long run.

These are details specific to the bottom line of their wine business, which plain and simple doesn’t have a “bargain basement” financial model to it no matter which way you slice it. So with that in mind we’ll talk a bit about the specifics of their wine business’ “who”. Who is going to buy their wine? And on a regular basis? How will they stay in front of that group of regular buyers? Why will someone want to buy their wine vs another producers?

How will they get their message out there in a field that is crazy crowded with product? Click To Tweet  

Anyone who is considering starting their own wine business must consider these topics and do some of their own research when they are getting started so they can begin to have an idea of what the financial scenario of their business is going to look like. These “who” details can start to give them an idea of how much revenue their business may generate, but then on the flip side of that I will also point out to them the expenses they need to be planning for to blend in (deliberate wine metaphor there) against those potential revenue numbers.

What are just some of the costs to at least be aware of related to starting a new wine business? Keep in mind the dollar amounts of each of these areas will vary depending on who you’re working with and/or the products you’re purchasing.

  • Purchasing grapes or bulk wine
  • Fees at winery site for processing your grapes and/or storing and bottling your wines
  • Trucking wine to/from winery site or wine storage sites
  • Fees at wine warehouse storage site (for your cased wines)
  • Wine packaging items (glass, labels, corks, etc)

 These are just some of the winemaking costs to plan for, some of the others being the costs of getting your necessary permits/licenses (My area!) to legally make/sell your wines, marketing costs, wine shipping costs, and fees to set up your business entity filings.

The statistic that is still seen related to new businesses success rates is that around 50% of them fail in their first 5 years. I wonder what that rate is for new wine business start ups.

Like to discuss your new wine business plans?  Let’s talk on one of my “Smart Start” calls.





CA Wineries: Don’t let your ABC license get suspended by this common mistake!
Posted on 2016-05-12 by Ann Reynolds

I hear frequently from winery staff here in California- frantically reaching out because their CA ABC type 02 license is either already suspended or in threat of being suspended. What was the source of this? Their lack of filing  a required report that all CA wineries must file: the CA Board of Equalization (BOE) Winegrower tax return. (see sample here)

This required report is for your excise taxes due to the CA BOE. All CA wineries hold a CA ABC type 02 license, which then means that they also hold a winegrower account with the CA BOE. (& FYI the CA BOE & CA ABC talk to each other related to all types of ABC licenses)

The BOE Winegrower report is the required report that all wineries must file. Many CA wineries will qualify to file this report listing zeros on the first page, which means then no excise tax payments are due to the BOE. However, it must still be filed regardless of the “zero” report numbers. This is the problem that arises for many, they simply are not filing this report.

What happens to wineries that don’t file this required CA BOE report? They start receiving notices from the BOE office warning them that their winegrower account is delinquent followed eventually by a notice that their account has been suspended. This suspension is in fact their CA ABC 02 license, which then means that their winery activities and sales are technically in suspension as well!

So no wonder that winery owners or their staff are frantic when they contact me. The solution to resolve these suspensions is generally fairly simple for someone like myself who knows exactly what to ask and to look for in their winery records. 

First of all we need to determine how their excise tax “flow” works for their business. Do all of their wine sales get shipped out of a wine storage warehouse on their behalf? An example of this is they bottle their wine then truck it “bond to bond” to their wine storage warehouse. When an order comes in for some of their wine it gets sent to the warehouse who then packs it up and ships it out. Because the wine went into the warehouse “in bond” this then means the warehouse is responsible for filing and paying BOTH the TTB (federal) as well as the CA BOE excise taxes on that wine shipment. The warehouse will then bill the winery back for those tax payments. This exact example is when their BOE winegrower report would list all zeros on the first page and then they would not be paying their CA excise taxes directly, but rather indirectly through their warehouse.

If however a winery does ever ship out wine FROM their winery site “taxpaid” this would then mean they are responsible for filing and paying BOTH their TTB & CA BOE excise taxes. This scenario might look like they send out some of their wine club shipments directly from their winery address.

Excise taxes are probably the most common area that wineries can get into trouble with, either at the federal level with the TTB or as in this post’s topic with the CA BOE and end up in the dreaded suspension status.

Questions or concerns about your winery’s excise tax status or filings and whether you’re managing them correctly?

Contact my office for a “Compliance Check in” call

 





CA wineries: Time to renew your ABC licenses
Posted on 2016-05-02 by Ann Reynolds

Here in California if you are in business as a winery, which is known as a “Winegrower” with our Alcoholic Beverage Control agency by now you would have more than likely received a mailing with your type 02 license renewals. The CA ABC gives numbers to all the different types of licenses they issue, and for those in the winery game they hold the type 02, or winegrower license.

First of all, I’ve always gotten a kick out of that term, “winegrower”. I always thought wine was made, and grapes were grown. However the license name was derived by the CA ABC folks once upon a time they are still rather old school with their renewal process. All type 02 licenses, which is called the Winegrower come up for renewal by June 30th of each year. These renewals are sent out, and must be returned via snail mail to the CA ABC headquarters in Sacramento. 

So a head’s up to all you California wineries- if you don’t receive this renewal mailing from the CA ABC by the end of May- give their Sacramento office a call 916-263-6882. You’ll want to provide them with your ABC license # as well. In case you can’t easily track down what that number is- here’s a link to look it up on their handy license query lookup

The CA ABC states that it isn’t their fault if for some reason their renewal mailings don’t make it successfully to your mailbox, and if they don’t receive your renewal mailing back post marked by June 30th they will tack on a ranging rate of late fee, which depends on what your license fee is. I also suggest sending your renewal back to their office in some form that you can track confirmation that they received it.

One other point worth mentioning here is that if your wine business is the “alternating proprietor” type you will hold a second type 02 license, called a duplicate. This will list whatever your businesses address is, which is different from your other type 02 license that lists the winery’s physical address. This second, or “duplicate” 02 license is also up for renewal by June 30th of every year- so make sure that you receive that renewal mailing from the CA ABC office as well. Here is where to contact them again if you don’t receive it by the end of May.  (916) 263-6882.





What the proposed alcohol range change means for your winery
Posted on 2016-04-18 by Ann Reynolds

Things are looking good for a major update coming for US wineries related to their excise taxes, 5120.17 report, and wine labels. The bill very appropriately named the wine excise tax modernization act  currently under review by congress and now with the support of Congressman Mike Thompson if passed will change the alcohol percentage range on the Table wine tax class.

Currently this still wine tax class covers an alcohol content range of wines from 7 to 14%. (*remember- this means that your wine’s alcohol content would round to 14.0%) With the passing of this bill the range would take a dramatic change to the upper end being 16%. This 2 decimal point change means big things for the majority of US wineries.

  1. It will take a chunk off their TTB excise tax bill. For a winery whose standard practice is to make wines that are always below 16% alcohol (remember- that means rounding to 16.0%) this will mean that instead of paying the higher $1.57 gallon current rate on any of their wines over 14% alcohol, they will now pay all their TTB excise taxes at the lower, “table wine” rate of $1.07/gallon. Now also add in paying their excise taxes under the small producers tax credit and the two will add up to hundreds or thousands of dollars in savings per year for most US wineries.
  2. It will change the way they maintain their required winemaking records, specifically their bulk and bottled wine inventory summaries of all wines they keep at their winery site. Currently wineries are required to be maintaining inventory summaries of all the bulk and bottled wine they store on site, and those summaries are required to track each lot of wine by it’s alcohol content, or TTB tax class.
  3. It will change how they complete their required report of wine premise operations, or 5120.17 report. On this report, like the above mentioned inventory summaries wineries report their winemaking activity numbers based on the alcohol content (tax class) of their wines. For any winery that has been completing this report manually will mean they’ll need to shift how they’ve been keeping track of their wine inventories by alcohol content to then be able to fill out this report per the updated alcohol content ranges of their wines. For wineries which use wine production database software to maintain their wine inventories and generate their TTB 5120.17 reports, the responsibility will fall mostly to their software providers to make the updates.
  4. It will change how they label their wines, specific to the alcohol content. Right now if a winery lists an alcohol content that falls in the table wine tax class (from 7 to 14.0%) then the actual alcohol percentage of that wine may only be within plus or minus 1.5%, without going over 14.0%. So if their label lists 13.5%, that currently means that if the TTB tested that wine for the alcohol content it would have to come back in the range from 12.0 to 14.0% to be in compliance. Now with this proposed change to the table wine’s alcohol range wineries will have more room to take advantage of in the plus or minus 1.5% tolerance range.

I definitely feel that this update to the table wine tax class has been needed for almost two decades now, so I’m glad to see this act at the final stage before becoming reality for TTB winery permit holders.

Stay tuned for more details on when this change would take effect if the bill passes.

Here’s a link to the latest post w/full info from Wine America





US Wineries: More savings may be coming for your TTB excise taxes
Posted on 2016-04-11 by Ann Reynolds

In January of this year came the announcement from the TTB that starting in January of 2017 many US winery TTB permit holders will no longer be required to maintain their TTB wine bond. See my blog post on this

Now just late last week comes another news update that offers even more significant excise tax consequences for all US wineries. WineAmerica posted about these updates on April 7th. They involve two major updates related to TTB excise taxes which are currently part of a bill recently revived and back under review by congress.

Here’s what these TTB excise tax changes would mean to your winery if the bill is passed:

The first major update of this bill would increase the small producers tax credit rate from 0.90 cents per gallon up to $1.00 per gallon. This credit amount of $1.00 per gallon would be available to wineries that qualify for the small producers tax credit on the first 30,000 gallons of wine they produce per year. A caveat here for all wineries to be aware of is the term “produce” in that statement. If its use is based on the TTB’s definition of “produced” then that would mean the $1.00 per gallon credit could be taken on only up to 30,000 gallons of wine that a qualifying winery “produced by fermentation”. (see my earlier blog post with the details on where those numbers actually come from) For an example of what the math looks like on this if a winery was submitting TTB excise tax payments on 30,000 gallons of table wine that it produced under the current 0.90/gallon credit amount it would owe $5,100 in excise taxes on that amount. Under the proposed $1.00/gallon credit amount it would instead owe $2,100 on that same 30,000 gallons. 

The second, and definitely in my mind the more major development included in this bill is that the alcohol content for the table wine tax class would be changed from it’s current range of between 7% & 14% alcohol (for still wines) to between 7% & 16% alcohol.  With that one change a MUCH larger percentage of wines that are bottled and/or sold on an annual basis by US wineries would then be taxed at the current table wine tax rate of $1.07 gallon. (*Note: wineries that qualify for the small producers tax credit as referenced above would then qualify to pay their TTB excise taxes on their table wines at .07 cents/gallon!)

The savings that will come for the majority of US wineries as a result of this bill being passed are significant

In my view it has been long overdue for the alcohol ranges of the two still wine tax classes to be updated to match the current winemaking world. Around the time that congress approved the current tax rates for still wines if a wine had an alcohol content of over 14% chances are it was a port or sherry, hence a “dessert wine”, which is the TTB’s name for that tax class of still wine between 14% & 21% alcohol. Up until roughly the late 1980’s into the early 1990’s most still wines produced at US wineries were below 14% alcohol. But by just a few years later that had progressively changed to a significant amount of still wines being well over 14% alcohol, due to changes in winemaking style, much of which was based on allowing the grapes to ripen much longer, therefore resulting in much higher sugar content at the beginning of fermentation and thus a higher alcohol after fermentation. Making wineries track, report, label and pay their excise taxes based on outdated regulations that no longer fit the current winemaking world has been long overdue.

One other area worth mentioning related to these potential TTB alcohol tax class changes is that wineries will need to make adjustments to their wine tracking and reporting processes. Whereas before all bulk or bottled wines produced, stored, bottled and reported on their winery site have been required to be logged by the current tax class ranges of 7 to 14% and 14 to 21% they will need to make edits to whatever their recordkeeping system is. Of course if they are a tech savvy winery which uses a wine production database software for their recordkeeping then the responsibility for these tax class tracking changes will fall to their software provider.

 





Wineries: Like to save $10,000 in taxes per year? (or more!)
Posted on 2016-04-04 by Ann Reynolds

Taxes. Always everyone’s favorite topic. Although when the topic is about things to do that result in dramatic savings on our taxes suddenly it becomes much more interesting. I recently gave a presentation at the Napa Valley Vintners Wine law forum where one of the topics that I covered was all about clarifying the specifics around how most wineries are NOT taking advantage of paying a MUCH reduced rate on their TTB excise taxes.

The short answer on this is if your winery is selling 5,000 cases of wine per year then you can qualify for $10,000 off of your TTB excise taxes due for those wines. (*As long as your winery ownership meet the qualifications- see my earlier blog post on those details) 

So for those 5,000 cases you sold in a year, instead of paying $18,664 in TTB excise taxes your winery could instead only pay $7,965. That’s a 57% savings! This savings comes from your winery and your wines qualifying for and taking advantage of the Small Producers Tax Credit.

There are two types of winemaking activities that you as a winery need to pay attention to related to how you will want to file your excise tax reports in order to correctly take advantage of these hefty tax savings since filing them incorrectly can lead to serious audit issues with much heftier late and underpaid fees due to the TTB!

Both of those two types of winemaking activities are related to whether or not your winery receives (& then bottles and sells) any wines from outside winery facilities. (Not under your own ownership)

What might that look like? Both of these are very common scenarios in the winemaking world. The first is if your winery has some wine made for you at another winery site that is then sent to your winery as finished wine. The second is if your winery purchases wine from the bulk market. If your winery regularly (or ever) practices either of these types of activities with wines made at another site then here is how to take advantage of that $10K per year tax savings.

You will want to make sure that you file and pay the TTB excise taxes on those wines (or the blends they go into) from your TTB permit number at your winery address. This will then also mean that if all your bottled wines go to an off site wine warehouse that you will need to send them “Taxpaid”

That is it. At least in the most simple terms. However since I realize that this is a topic that is still commonly misunderstood definitely reach out to my office for clarification on your winery’s TTB excise tax dynamics and we can discuss what sorts of annual tax savings you can take advantage of.

707-266-1946  or ann@winecompliancealliance.com





US Wineries: Do your WINES qualify for the small producers tax credit: Part 2
Posted on 2016-03-30 by Ann Reynolds

In last week’s post I wrote about how to determine if your winery qualifies to file and pay your TTB excise taxes under the small producers tax credit (SPC). There are two main areas that need to be understood related to qualifying for the SPC, the first is whether your winery qualifies (the focus of last week’s post) and second (if the answer to the first part is yes) whether your wines themselves qualify. That is the focus of this week’s post.

Even though your winery may meet the requirements for the SPC that doesn’t mean that all of the wines you bottle will. Here is where you need to be keeping a close tab on the individual winemaking details behind each final blend of wine you bottle for sale. Before clarifying what I mean by this I also need to point out that from a winemaking perspective one of the other main requirements of the SPC is showing wine production every year. Not sure what is meant by “wine production”? See my earlier post here

In taking a look at any of your individual wines that TTB excise taxes are due to be paid on here is the question flow to walk through:

  1. Did we produce all of this wine at our winery? Translation: Were all of the gallons in this wine blend once listed on line 2, Produced by fermentation of our TTB 5120.17 reports? If the answer is definitely yes then the wine will qualify for the SPC.
  2. If your answer is part yes and part no then you’ll need to dig into the details of the “no” gallons. For those gallons that were not “produced by fermentation” at your winery site where were they produced?
  3. Were they produced for your winery by another winery site under a custom crush type of arrangement? If the answer is yes then they can qualify for the SPC but ONLY if you remove their gallons from your winery site as taxpaid, which then means that your winery site files and pays the TTB excise taxes due. This is especially important to point out for all wineries that follow the very common route of sending their cased wines “in bond” to a wine storage warehouse and have them file and pay their TTB excise taxes.  I refer you to a good article on a case from 2015 where this very scenario was the issue that caused a winery a 6 figure late tax bill.
  4. REVISED from Feb 15 posting. Were the “no” gallons a purchase from the bulk wine market? If this is the scenario then those gallons may or may not be eligible for the SPC depending on who files the TTB excise taxes on the bottled wine blend they go into. In order to keep in compliance with filing your TTB excise taxes correctly (under the SPC) for a wine blend that contains those bulk purchased gallons your winery again would need to file and pay the TTB excise taxes for them from your winery bonded site and thus send them to your wine storage warehouse “taxpaid”.  Same scenario as the above example in # 3.
  5. The main significant difference to be aware of here in either of the two scenarios above where your winery owes TTB excise taxes on wines you did NOT produce is that if those cased wines are sent to your warehouse “In Bond” then ONLY the gallons that were produced at your site will qualify for the SPC. Your warehouse would need to be informed  of the percent of your wine blend that does qualify for the SPC. Here’s an example with some math to show what I mean by this. Your winery bottles 5,500 gallons of a blend that 3,465 gallons is wine you produced and 2,035 gallons is wine that was purchased from the bulk market. That would mean when you send this cased wine in bond to your wine storage warehouse you’d need to include on the documentation (the bill of lading)  prominent wording which states that only 63% of it qualifies for the SPC. So when the warehouse then files and pays the TTB excise taxes on it they’ll pay them at the SPC rate on only 63% of the amount of wine shipped.
  6. Your excise tax savings in the long run are significant if you send these “combo” wines to your warehouse Taxpaid. For the above scenario of the 5,500 gallon blend the tax savings would be $4,950 vs  $3,119, which would mean your total tax bill due to the TTB on the 5,500 gallons would either be $3,685 or $5,517 almost a $2K savings.  Certainly for a wine blend like this one I’d recommend it.

As you can see following all the ins and outs of the SPC is no simple task. US Wineries need to be familiar with it however, as it can either save them or cost them a significant amount.

Questions about your winery’s TTB excise taxes? Full contact info for my office is here.

 

 





Interacting with the TTB part 2: Permit application filings
Posted on 2016-03-20 by Ann Reynolds

This post is number 2 following up on my blog from 3 weeks ago in which I shared my tips for successfully interacting with the TTB’s main office in Cincinnati if you have questions related to your winery’s  TTB permit or reports. That area however is just one leg of the overall successful management of any winery’s TTB compliance. The other leg is what I’ll share my tips for today. Specifically the topic I refer to is either an original application for a new winery or wine wholesaler business or an amendment type of filing if you’re already an existing TTB permit holder.

During the process of submitting an application to the TTB, either when you are starting a new wine business or if you already hold a TTB winery basic permit and need to update the ownership details, or your bonded premise area or are moving from one premise address to a new one (all examples that require a permit amendment filing)  there are specific steps in the preparation and follow up process that knowing ahead of time will make it go much smoother and more than likely faster.

Here are my tips sectioned out by the two areas of applications submitted to the TTB.  As in my earlier post the TTB office you are interacting with is their National Revenue Center (NRC) office in Cincinnati, Ohio.

Applications for a new TTB permit using the Permits Online system:

  1. If you are responsible for filing a TTB application first make sure that you have power of attorney for your winery’s permit so that you will be able to interact with the TTB staff for this necessary follow up. (A TTB power of attorney form can be submitted as part of submitting a new permit application)
  2. Pay attention to the current approval time frames for your application type and make a mark out on your calendar for around 2 to 3 weeks before the end of that current approval cycle and call their offices (855-882-7665) and press 2. When you actually get through to a live person tell them you are calling in reference to your Permits Online application tracking # and the name of the business on the permit application. 
  3. They will then be able to give you the name and contact # for the TTB specialist who is handling your application. TTB email format by the way is: firstname.lastname@ttb.gov
  4. Reach out to them by phone and if you are successful in reaching them directly reference who you are, the Permits Online tracking number for your application and the business name. Let them know that you are checking in to confirm the approval status of your application and whether or not anything else is still required on your end to complete their review and approve it.
  5. If you have to leave a voicemail then also follow up by sending them an email w/the same request.
  6. If you don’t receive a response back in a week then reach out again.
  7. Once you have established contact with the specialist handling your application make sure on your end that you are responsive to any additional requests they have regarding your application. If an email is sent to you try to respond back the same day. 

Existing TTB permit holder amendment applications:

  1. The first step is specific to how your original TTB permit application was filed. Was it submitted via mail in hard copy form to the TTB offices or was it submitted (after early 2011) via their Permits Online system? Depending on which of these it was will then determine how you continue to submit all amendment application filings moving forward. So you’re either “old school” (hard copy, snail mail) or “new school” (permits online- everything sent electronically) .
  2. Once you’ve determined your answer to #1 the next step is to prepare the information or forms you’ll need to submit with the application. Here’s a handy reference list of required permit amendment filings “after original qualification” as the TTB calls it. This list is useful to both snail mail and online filers, however in the case of a winery that is filing using the Permits Online system some of the required forms on this list won’t apply, but rather you fill in the required information via the TTB’s online forms.
  3. If you are submitting via hard copy, snail mail make sure to create a duplicate set of the completed application forms to send in. I also recommend that when your applications are ready to send in that they are sent with some form of delivery confirmation so you know when they arrived safely at the TTB offices. 
  4. Follow up. Give it at least 4 weeks after the date you know your application was received before beginning making any contact w/the TTB offices. Here again you’d call their main contact # of 855-882-7665 and press # 2. Tell the person the details of your winery’s TTB BW #, business name, the date your application was received into their offices, and that you are calling to confirm it’s review status. If they can they will give you the name of the TTB specialist handling your file.
  5. Once you know the TTB specialist with your application you can follow you can follow steps 4 through 7 from above to make contact and follow up through your application’s approval.

My final tip across the board for TTB applications:

  1. Be persistent- but not a pest! And in the process of being persistent be professional. (consider yourself a diplomat for your winery)
  2. Be aware that there are many new staff members at the TTB offices, many of whom are brand new to the winery regulation world. So the more familiar you are with what forms, information and documentation are true requirements vs. what is not is valuable knowledge to have. 




Winery Compliance Class in Napa: April 12th
Posted on 2016-03-14 by Ann Reynolds

The requirement for Napa County winery use permit holders to submit annual reports is getting closer to going into effect. A training which will cover this topic and others specific to TTB winery compliance is coming up on Tuesday, April 12th.

This class is a way to  take a look at your winery’s compliance “health”. Is it in good standing? Are you keeping your wine making records correctly to pass either a TTB or a Napa County planning audit?

If you have ever lost sleep over the above topics- I’m teaching a class next month which is designed to help you find out.

The class isHow to keep your winery Audit safe” and is being offered on Tuesday, April 12th from 9 til noon through the Napa-Sonoma Small Business Development Center (SBDC).

Go HERE for full details & to sign up. 

It will be offered at the SBDC office on the Napa Valley College campus.

The class will focus specifically on key issues related to TTB (Alcohol & Tobacco Tax & Trade Bureau) and Napa County Planning use permit required reporting potentially scheduled to come into effect in 2018. These are items that come up most frequently in the course of on site audits by both of these regulating agencies. Topics such as required records and reporting, excise tax payments, and how to determine production levels will be explained and reviewed so attendees can then determine whether their winery has any potential issues that need to be addressed.

Winery staff attending the class are highly encouraged to bring the following items:

  • Full previous years TTB 5120.17 (“702”) reports
  • Most recent TTB excise tax report
  • Examples of required records: a completed bill of lading for cased wine & one for bulk wine
  • Current Napa county Use Permit with details of your production gallons and if your permit has a grape sourcing condition.

This class will go a long way to help wineries fully connect the dots as to how the records and reports they are required to be maintaining and filing either have potential audit holes in them, leaving them vulnerable as well as specific steps they can take now to address them.

Here is a link to get signed up:    Winery Compliance Class

 





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