The TTB (Alcohol and Tobacco Tax and Trade Bureau) regulates US wine production, requiring detailed record-keeping and periodic reporting. For small and medium wineries, navigating TTB requirements can be overwhelming, especially without dedicated compliance staff.
Required Records
Wine Production Records
- Crush report: grapes received by variety, grower, weight, Brix.
- Fermentation record: tank, variety, volume, start/end dates.
- Cellar treatment record: all additions and treatments (SOβ, fining, filtration).
- Blending record: components, volumes, resulting blend.
- Bottling record: lot, volume, date.
Inventory Records
- Beginning and ending inventory by product type.
- Gains (production, purchases).
- Losses (sales, samples, breakage, evaporation).
Transaction Records
- All purchases and sales of wine.
- Transfers between bonded premises.
- Removals for consumption or destruction.
Required Reports
Monthly Report of Wine Premises Operations (TTB Form 5120.17)
Due by the 20th of the following month, this report summarizes:
- Wine produced, received, removed, and on hand.
- Broken down by tax class (table wine, dessert wine, sparkling).
Excise Tax Return
Wine excise tax varies by type:
- Still wine (β€14% ABV): $1.07/gallon.
- Still wine (14-21% ABV): $1.57/gallon.
- Still wine (21-24% ABV): $3.15/gallon.
- Sparkling wine: $3.40/gallon.
Small wineries producing <250,000 gallons qualify for tax credits.
Common Compliance Pitfalls
- Late reporting: the monthly report is due by the 20th. Late filing can trigger penalties.
- Inventory discrepancies: physical inventory must match records. Unexplained differences trigger investigations.
- Inadequate cellar treatment records: every addition must be logged. "I sulfited all the reds" isn't sufficient documentation.
- AVA documentation gaps: claiming an AVA on the label without adequate grape origin records.
- Blend documentation: failing to record blend components makes label claims unverifiable.
Cepaos and TTB Compliance
Cepaos records all winery operations in a structure that supports TTB compliance:
- Crush, fermentation, treatment, blending, bottling records.
- Inventory calculated automatically from movements.
- Data for the monthly report generated from recorded operations.
- AVA tracking from grape receipt to bottle.
Compliance shouldn't be a separate project. It's a byproduct of good record-keeping.