It is already May and looking back over all the posts I’ve shared this year it isn’t too surprising they are all focused on the changes impacting US wineries specific to their TTB reporting and excise taxes. Because these TTB changes are rather involved I’m finding more topics continue to come to mind to create additional posts designed to clarify the specifics on how wineries are impacted.
The next topic that came to mind is related to a regular activity that happens at US wineries. The transfer of bulk wine. Wineries will often decide to bring in wine that was originally made (produced!) at another winery site and then use some or all of that outside wine as part of one or more of their own bottling blends.
This has been a very common occurrence for years and up until January 1, 2018 wineries could take advantage of TTB tax credits off those outside wine gallons in addition to all the gallons they produced themselves at their own winery sites.
Sorry folks- no more! If your winery site receives in any bulk wine gallons and then bottles any of those gallons, either with or without some of your sites own “produced” gallons none of the outside gallons will meet the current requirements for deducting tax credits off TTB excise taxes.
I found this article while looking into state/federal compliance for bottling and reselling bulk wine as a hobby. I have no experience in this, but the technical process seemed to be relatively straightforward. I had planned to start very small (10 gallons?). Unfortunately, from what I’ve learned so far from VA ABC compliance officers and online, it seems that if I decide to sell even a single bottle of wine, then I’ll need to sell several hundred just to cover the costs of meeting regulatory requirements (just the paperwork). Because of this, I guess I’ll only I’ll only be doing the bottling for personal use, if at all. Very disappointing.
Hi Paul – thanks for your comment. Yes, that’s essentially what it comes down to, as soon as any type of alcohol is being sold then the seller must hold a license that allows them to do that. On the other hand you can make and give away as much as you want!