Wine making compliance has a lot of moving parts. Those moving parts primarily consist of the records that detail the activities that happen to a wine throughout it’s “life”, generally from grape to bottle though it could also be a much shorter story.
These (required) records consist of 3 main items; weigh tags, work orders and bills of lading. Any winery will need to have at the least 2 of these in their files, and would be required to produce them in hard copy form in the event of a TTB audit.
In my experiences most wineries are not aware of the specifics that the TTB requires to be tracked on each of these required records. Unfortunately, winery staff are often not given any or enough training related to TTB compliance in order to do that part of their jobs effectively.
Taking a look at each item separately here are some quick run-down questions for winery staff to ask when assessing each of these records in their files.
Item 1. Weigh Tags. This record as an official state of California (CDFA) document is called a weighmaster certificate. A weighmaster certificate is required for any sales transaction of grapes, juice or bulk wine. A weighmaster certificate has a specific set of items that it must contain. (see sample here under weighmaster certificate requirements)
From the TTB’s perspective however a weigh tag is essentially a birth certificate for a wine.
1. Do your weigh tags document the AVA for the grapes used to make your wines?
2. Do your weigh tags document the specific vineyard names for all your grapes?
These are two items that are NOT required to be documented on a weighmaster certificate, but wineries want to include them to make the connection between their weigh tags and their wine labels. Both AVAs and vineyard names are commonly listed on wine labels, and the easiest way to satisfy the TTB during an audit is to have them included on all the weigh tags for your grapes.
Item 2. Work orders. Work orders are the records that track each activity that happened to a wine throughout its life at a winery site. They track the crushing, pressing, movements, addition materials added, blendings, filtrations, bottlings, etc that happen from start to finish in the wine making process. Gains and losses are documented on these.
1. Do you have hard copy work orders that include the date, tank/barrel info, blend/lot numbers, and start/ending gallons for your wines that document all wine making activity for each of your wines from “start to finish”?
2. Can your work orders be connected one to the next for your wines, so that blend #’s match, starting/ending gallons match and any excessive losses are documented?
3. Are you tracking your finished wines by their accurate tax class? (Either below 14% or over 14 to 21% alcohol)
Item 3. Bills of Lading. A bill of lading, or BOL as they’re referred to by industry is what the TTB refers to as a “Transfer in Bond” record. When a winery receives in or ships out bulk wine a bill of lading is required for that wine shipment. There is a specific set of items that the TTB requires to appear on any Transfer in Bond record. (See list here)
1. Do your winery’s BOLs contain: Your TTB BWN number AND the receiving winery’s BWN (or BWC) number? And full physical address for both?
2. Do both your BOLs and the BOLs you receive from other wineries contain the FULL breakdown on the wine: Vintage, Varietal, & Appellation- all adding up to 100%?
3. Do both your BOLs and the BOLs you receive from other wineries list either the actual alcohol content OR at a minimum list the tax class? (below or over 14%)
The three wine making records described above are what tell the real stories of a wine’s life. The details that they track become the numbers that wineries report on the TTB Report of Wine Operations report, the details that (in part) document whether a winery qualifies for the Small Producers Tax credit, and what a wine will or won’t qualify to list on its label. These are all topics that come up most commonly during on site TTB winery audits.