Category Archives: Current Topics

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.

Continue reading





“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)

Continue reading





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?

Continue reading





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!

Continue reading





2012 Winery Compliance Wrap Up…….& What To Watch For in 2013.
Posted on 2012-12-30 by Ann Reynolds

Here we are at years end. A time often focused on assessing the years events & developments, ups and downs. For the winemaking world 2012 has already been marked as an incredible one in relation specifically to the grape harvest. (At least here in California) But what about in relation to compliance? What were the stories there? And what’s to come for wineries in 2013 that they’ll want to pay attention to for keeping on top of their compliance?

Continue reading





Wineries – Are You Out of Bounds on Your Bond?
Posted on 2012-11-08 by Ann Reynolds

I recently wrote a post about one of the potential compliance side effects related to this years high yield harvest. Afterwards, while I was talking to a client I was reminded of another potential compliance issue. He asked about the topic of bond coverage and what happens if wineries go outside their limits.

First, let me put all of that into laymans terms and how it ties into this years high volume harvest. All wineries have specific bond coverage (TTB requirement) which is an insurance policy that covers the total tax liability for wines they have on their site at any given time. If their total volume goes over that coverage amount  in the event of an accident or  an audit they would be outside their coverage amounts on their TTB reports. In both cases something they can be fined for or worse, held responsible for tax liability on wine that accidentally was lost.

Continue reading





Winemakers – It’s 3 am, Do You Know Where Your Grapes Are?
Posted on 2012-10-25 by Ann Reynolds

Harvest of 2012 has definitely shaped up to be a very welcome banner year for wineries here in California. I’ve been reading story after story about the high tonnage amounts, and picture perfect looking fruit that has been arriving at wineries over the past two months. But what happens when too much of a good thing is showing up at your winery? That is you’ve got more fruit ready to come in than you’ve currently got tank space open to ferment it in?

Continue reading





Planning For A Wine Business: CC Client VS. Alternating Proprietor
Posted on 2012-08-23 by Ann Reynolds

I talk to a lot of people who are just getting started with a wine business. Many of them are either starting as a custom crush client (wholesaler) or as an alternating proprietor.  (See my two previous posts)  No matter which of these types of licensing they are getting I always start out  our conversation by asking them questions about what their business model is going to look like. Why am I so curious about their business model? Continue reading





Compliance Lessons Part 2: What Alternating Proprietors Need to Know
Posted on 2012-08-16 by Ann Reynolds

Last week’s post was a milestone for my website. The post on custom crush compliance lessons has received (as of this writing) over 1,000 viewings! It was a definite rush for me to see this response but it also tells me (reminds me really) that there are a lot of behind the scenes compliance details that both custom crush clients AND wineries need to be aware of. A particular section of wineries for follow up focus is alternating proprietors. (APs) An AP is basically a “winery within a winery”. There are distinct differences between an AP and a custom crush client at a winery. Wineries- Do you KNOW what those are?

Continue reading