The annual reporting requirement for all Napa County winery use permit holders just took another step closer to being in effect. This reporting requirement is part of the APAC recommendations still being reviewed and finalized by the Napa County Board of supervisors and planning office.
One of the results of the supervisors meeting last week was further honing of the details behind the APAC recommendation for an annual “self certification” program for all Napa County winery use permit holders. Currently Napa County wineries are not submitting any annual reports to the county office related to their wine production numbers. (though some are already required to submit their 75% grape sourcing numbers)
The first phase of this required reporting could start being implemented in 2017. This initial reporting requirement would be on the winery’s “production” and grape sourcing numbers. The county will be reviewing their current formula for determining a winery’s “production” gallons, which are tied directly to the numbers they report on their TTB 5120.17 reports. See my earlier blog post on the specifics of this calculation.
For those reading this who are wondering about their own winery site’s compliance with their Napa County use permit a training opportunity is coming up next month on April 12th from 9 til noon at the Napa Sonoma Small Business Development offices on the Napa Valley College campus.
The course, “How to keep your winery audit safe” will address the Napa County winery use permit topics mentioned above on wine production and grape sourcing and will also address common TTB winery audit issues such as the 5120.17 report and excise tax issues related to qualifying for the small producers tax credit. Full course info and sign up link is available here.
This required wine production and grape sourcing reporting requirement will be just the first phase of the self certification program suggested by the APAC. The second phase would address some of the other areas of a winery use permit such as tasting and marketing events.
Winery owners and staff need to also be aware that until these compliance reporting programs are in effect that the random 20 audits per year will continue to be part of the county planning office’s schedule. The results of their 2015 random audits did show that 3 wineries were out of compliance related to either their production or 75% grape sourcing numbers.