The Alcohol and Tobacco Tax and Trade Bureau (TTB) regulates every aspect of wine production and sale in the United States. From permits to labeling, from record-keeping to excise taxes, TTB compliance is not a one-time event, it is an ongoing operational requirement that touches every part of your winery.
The Permit Foundation
Every US winery needs a federal Basic Permit (27 CFR Part 1) and a Bonded Winery permit before producing or selling wine. The application process involves:
Application to Establish and Operate Wine Premises (TTB F 5120.25) : covers the winery's physical location, equipment, ownership structure, and planned operations. The separate Application for Basic Permit (TTB F 5100.24) under the FAA Act is filed alongside it.
Bond requirement : under the PATH Act (effective January 1, 2017), a winery is exempt from the bond requirement if it was not liable for more than $50,000 in excise taxes in the prior year and reasonably expects to owe no more than $50,000 in the current year. The threshold is tax liability, not gallons produced. Operations above that level must post a bond.
State licenses : every state has its own licensing requirements on top of the federal permit. Some states require separate licenses for production, wholesale, and retail.
Record-Keeping Requirements
TTB requires detailed records of all winery operations:
Production records : grape receipts (weight, variety, vineyard source, AVA), crush operations, fermentation, blending, fining, filtering, bottling. Every action that transforms the product must be documented.
Storage records : wine inventory by type, class, and tax status. Wine in bond (not yet taxed) must be tracked separately from tax-paid wine.
Transaction records : all sales, transfers, exports, and removals. Each transaction must reference the specific wine lot and include quantity, recipient, and date.
Tax records : excise tax calculations, credits, and payments. The current federal excise tax rate is $1.07 per wine gallon for still wines up to 16% alcohol (with reduced rates for small producers).
Reporting Obligations
Monthly Report (TTB F 5120.17) : due by the 15th of the following month. Summarizes production, storage, and removal activities. This is the core compliance document.
Excise Tax Return (TTB F 5000.24) : filed semi-monthly, quarterly, or annually depending on your tax liability. Semi-monthly is the default; quarterly is allowed for liability of $50,000 or less, and annual for liability of $1,000 or less. Most small wineries file quarterly.
Annual Filing : operational reports and any required certifications.
Common Audit Triggers
TTB conducts both routine and targeted audits. The most common triggers include:
Inventory discrepancies : significant differences between reported inventory and physical stock during field visits.
Late filings : consistently late monthly reports signal compliance issues.
Labeling violations : using an AVA without meeting the 85% grape sourcing requirement, or vintage-dating without 95% of the stated vintage.
Excessive losses : wine losses beyond normal evaporation and processing ranges trigger closer examination.
How Cepaos Supports TTB Compliance
Cepaos tracks every winery operation from grape receipt to case shipment, generating the records TTB requires as a byproduct of normal operations, not as a separate compliance exercise.
- Automated monthly report data aggregation
- Lot-level traceability from vineyard to bottle
- AVA percentage calculations for every blend
- Excise tax computation with small producer credits
- Audit-ready record export
Cepaos: If you'd like to try Cepaos through the founding members program, review the eligibility requirements.
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