If I asked you “is your winery up to date in filing all your TTB reports?”, would you have a confident yes as a response? Or would you pause, and respond with an unsure “uhhhhhhh” or worse yet “what TTB reports?”.
Well US wineries the TTB is now starting to catch up with any of you in the last two answers above. How are they doing this? They’re catching you out when you submit a new application to make some type of update to your winery’s TTB basic permit file. (I give an example of this later in this post) In the process of reviewing that application the specialist assigned to it will reach out to you and inform you that in order to continue processing your application they must receive any outstanding reports. Sly TTB!
I shared about this new action on the TTB’s part in my post from Jan 5th this year. That blog was about when winery’s change ownership, however I can speak from first hand experience that they are also cracking down when a winery files other types of basic permit application updates.
Recently my office filed an application for a business that was a new alternating proprietor (AP) client at a local winery site. As part of this type of application the “host” winery is required to submit an application to the TTB to add the new AP client to their site. The AP client then files their own application to the TTB connecting it to the host’s application via a tracking number. When the TTB was reviewing the host winery’s application they discovered that they were not current with their reports, specifically some of their excise tax reports. The TTB informed the winery that they were required to file all of those past due reports before the specialist would continue processing their application to add the new AP client.
That is just one example I’ve experienced so far, but I’d expect to continue experiencing them because I know there are plenty of US wineries that are not current with their required reports. Not sure what the filing requirements are for the TTB reports? See this summary page from the TTB’s site.
Still not sure about your winery’s reporting requirements and would like to have some peace of mind? You can talk with me directly by setting up a Compliance Check in call to review what the reporting specifics are for your winery.
Has your winery experienced this when submitting an application to the TTB? Share your experience in the comments below – misery loves company!