TTB audits happen. When they do, auditors ask for production records, tax reports, and label documentation spanning years. The winery with everything in a searchable digital system beats the one hunting filing cabinets every time.

The United States is the fourth-largest wine producer and the largest wine market in the world by consumption. Whether you run a 5-acre estate in Sonoma or a 500-acre operation in the Central Valley, the Alcohol and Tobacco Tax and Trade Bureau (TTB) sets the rules for production, labeling, and record-keeping. For small and mid-size wineries, TTB compliance is straightforward in theory. In practice, it becomes time-consuming when records are scattered across spreadsheets, paper logs, and the winemaker's memory.

This guide covers what auditors actually check, why digital traceability survives audits faster, and which recordkeeping rules most wineries get wrong.

What the TTB Requires

Basic Permit and Bond

Every winery needs a TTB Basic Permit (or alternating proprietor arrangement). Bonded winery premises must be registered, and production must occur within the bonded area.

Production Records (27 CFR Part 24, Subpart O)

TTB regulations require wineries to maintain detailed production records. These documents establish the movement and quantity of materials at every step:

Crush records - variety, source vineyard, tons received, Brix at harvest, date of receipt
Fermentation records - tank assignments, yeast additions, fermentation temperatures, volume upon completion
Cellar treatment records - SO2 additions, fining agents, acid adjustments, blending decisions with dates
Bottling records - lot number, volume, date, label approval number, fill tests, alcohol tests per lot

Records may be handwritten, typed, or digital. TTB does not prescribe a format, but they must accurately reflect wine operations and be accessible during audit.

Tax Determination and Reporting

Wine is taxed based on alcohol content and type (still, sparkling, hard cider). Wineries must file:

TTB Report of Wine Premises Operations (Form 5120.17) - filed monthly, quarterly, or annually depending on inventory size and tax liability. Wineries with fewer than 20,000 gallons on hand at any time file annually (due January 15). Those with 20,000-60,000 gallons file quarterly (April 15, July 15, October 15, January 15). Wineries exceeding 60,000 gallons or paying more than $50,000 in federal excise tax annually must file monthly.
Excise tax payments - based on gallons removed from bond
Physical inventory counts - at least annually, reconciled to your reports

Labeling (COLA)

Every wine label must have a Certificate of Label Approval (COLA) from the TTB before it can be sold. The COLA verifies that the label meets all regulatory requirements: appellation, variety percentage, alcohol content, health warnings, sulfite declaration, bottler/importer info, and barcode.

COLA applications are filed online through TTB's COLAs Online portal and typically approved within 5 to 20 business days.

AVA Compliance: The 85% Rule and Beyond

The American Viticultural Area (AVA) system governs geographic designations on wine labels. If your label says "Napa Valley" or "Willamette Valley," the TTB requires:

85% of the grapes must come from the named AVA
75% of the grapes must be the variety named on the label
95% of the grapes must be from the vintage year stated

Tracking these percentages requires vineyard-to-bottle traceability, especially when blending across vineyards, varieties, and vintages.

"The 85% rule is a floor, not a ceiling. Many premium producers track 95%+ to enable stricter labeling claims and differentiate in market." — US winery operations analyst

State-Level Regulations: DTC Shipping and Beyond

Beyond the TTB, each state has its own alcohol regulatory body (ABC in California, OLCC in Oregon, LCB in Washington). Requirements vary by state and can include additional reporting, licensing, and direct-to-consumer (DTC) shipping permits.

For wineries that sell direct-to-consumer across state lines, compliance with each state's shipping laws is a significant administrative burden.

Recordkeeping: TTB, FDA Bioterrorism Act, and What Matters

TTB production records vs. FDA food traceability rules: Many winemakers confuse these two systems. TTB owns your production and tax records. The FDA's Bioterrorism Act recordkeeping, by contrast, focuses on ingredient sources and customer destinations, not the internal cellar process.

TTB Records: Production and Tax

TTB requires you to maintain production records and file Form 5120.17. An auditor will verify that:

Quantity and movement of materials (grapes, juice, wine, additives) can be traced through daily transaction records
Source documents (pick slips, invoices, bills of lading, lab results) exist and are accessible
Monthly 5120.17 reports reconcile to physical inventory counts
Label records show varietal, vintage, appellation, and analytical data

FDA Bioterrorism Act: Source and Destination

Wineries must register with the FDA and maintain records identifying the immediate previous sources (grape suppliers, bottling facilities) and immediate subsequent recipients (distributors, retailers, direct customers). You must provide this documentation on request.

FDA FSMA 204 Traceability Rule: Not Your Problem (Yet)

The FDA's Food Safety Modernization Act (FSMA) Section 204 establishes traceability recordkeeping for certain foods on the Food Traceability List. Current examples include leafy greens, berries, and certain dairy products. Wine is not currently on the Food Traceability List, so FSMA 204 does not apply to wineries today. Monitor this for future updates, but it is not a compliance requirement in 2026.

Why Digital Traceability Matters

Importers expect it. US wineries that export, particularly to the EU, Japan, or Korea, face documentation requirements from the importing country. A European importer will ask for full lot traceability before signing a purchase order.

Audits require it. TTB audits are not frequent, but they are thorough. When they arrive, auditors ask for production records, tax reports, and label documentation going back several years. A searchable digital system beats filing cabinets every time.

Your team will thank you. When the winemaker, lab tech, and bookkeeper each maintain their own records, reconciliation is manual, error-prone, and exhausting. A single digital platform makes traceability automatic.

How Cepaos Helps US Wineries

Cepaos provides vineyard-to-bottle traceability in a mobile-first platform designed for working winemakers, not IT departments:

Crush and cellar records from your phone, in the cellar
AVA compliance tracking: automatic percentage calculations for variety, origin, and vintage
Lab results linked to each lot
Cost tracking from vineyard to shipping dock
Wine club management with recurring billing and subscriber analytics
Audit-ready exports: all records, source documents, and reconciliation in one place

Try Cepaos free →

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