Anybody out there at all confused by what exactly a TTB wine bond is? No surprise there. The area of winery compliance is a constant source of confusion for winery owners and their staff. I hear about it all the time as a winery compliance consultant.
As of late there has been a lot of press around the upcoming update for US wineries and wine cellars that will qualify to cancel their TTB wine bond starting in January of 2017.
My office is hosting a webinar on that very topic on Wednesday, December 7th. This blog will serve as a sneak peek of sorts into some of the details we’ll go over on the webinar.
What exactly is a TTB wine bond? Up until now any applicant for a TTB basic permit as either a winery (“BWN”) or a wine cellar (“BWC”) has been required to set up a wine bond as part of their original permit application. They did this either by having an insurance policy set up through their insurance provider or they submitted a cash payment for the full bond amount. The appropriate details of whichever type they chose were included on their completed TTB wine bond form that was submitted with the application.
What is the purpose of a TTB wine bond? A wine bond serves the purpose of covering the permit holders TTB excise tax liability on two groups of their wines. First it cover this excise tax liability on all “in bond” wines that are physically sitting at their site at any given time across a calendar year and second it also covers the “tax deferral” amount due which is for bottled wines the site has either shipped out to customers or “removed taxpaid” to another premises. Essentially the purpose of a wine bond has been to ensure that the TTB can collect on its excise tax revenues in the event a permit holder flakes or has a significant loss due to an accident.
What a TTB wine bond is not! A wine bond as mentioned earlier is just one required item in the permit application file of any US winery or wine cellar. Many have contacted my office to ask if this update means that they won’t need a TTB permit anymore. It does NOT mean that! The confusion is coming in because of our use of the term “bond” in the winery world. We regularly use expressions such as “what is your wine bond?” or “Our winery bond is XYZ” when what we are actually talking about is a site’s TTB registry number. This is the number that will begin with either “BWN”, “BW”, or “BWC”. It will look like “BW-CA-####” or “BWN-CA-#####” or “BWC-CA-#####”.
This number by the way is THE number that US wineries or wine cellars will (& must) use on their reports such as the 5120.17, excise tax and label approvals. Plus any other correspondence w/the TTB. Many wineries and wine cellars will mistakenly use the other number listed on their TTB basic permit which looks like: “CA-W-####”. (example is for California) This mistake is understandable, since if you look at an actual TTB basic permit this number is actually titled “permit number” on that document. However their “BW” or “BWN” or “BWC” is what the TTB calls their registry number and it appears in box # 3 of their basic permit.
To find out the details around whether or not your winery or wine cellar will qualify to cancel your TTB wine bond in January of 2017 here is a link to the webinar coming up on Wednesday, December 7th at 1 pm PST Space is limited so sign up soon if interested!