The TTB (Alcohol and Tobacco Tax and Trade Bureau) regulates US wine production with one non-negotiable mandate: prove it. Every gallon fermented, every blend made, every bottle sold must be documented. For boutique and small production wineries, these records are the difference between audit-free operations and penalties that can cripple a young business.
This guide walks you through exactly what the TTB requires, when it's due, and what happens when it's not.
Records You Must Keep
Harvest and Production Chain
- Crush report: variety, grower source, weight received, Brix/sugar level at arrival.
- Fermentation records: tank ID, variety, volume, fermentation start and completion dates, temperature if relevant.
- Cellar treatment log: every addition (SO₂, bentonite, tartaric acid, enzymes, yeast strains). "Sulfited the reds" isn't documentation; TTB auditors need specifics.
- Blending worksheet: components by lot, exact volumes, resulting blend tank, date blended.
- Bottling records: production lot, volume bottled, bottling date, any lot splits for labeling variants.
Inventory and Accounting
- Beginning and ending inventory: by wine type (table, dessert, sparkling), measured in wine gallons.
- Gains: production volumes, purchased wine, transferred-in from other bonded premises.
- Losses: sales removals, samples given to consumers or trade, breakage/spillage, destruction, evaporation losses.
Supply and Sales
- Purchase records: vendor, wine type/vintage, volume, date received.
- Interplant transfers: movement between bonded premises, documented with TTB Form.
- DTC and wholesale removal records: buyer, date of removal, quantity, tax class, shipping documentation.
The clock starts the moment grapes hit your crush pad. If it's not in your cellar log, the TTB assumes it never happened.
Reports That Drive Compliance
Monthly Report of Wine Premises Operations (TTB Form 5120.17)
This is your primary operational report. It summarizes:
- Total wine produced, received, and removed during the month
- Beginning and ending inventory
- Breakdown by tax class (table wine, dessert wine, sparkling wine)
- Adjustments for losses, samples, and interplant transfers
Who files monthly?
- Wineries with more than 60,000 gallons on hand at any time during the year, OR
- Producers paying more than $50,000 in federal excise tax annually
Quarterly option (if eligible):
- Due April 15, July 15, October 15, January 15 (for operations with <60,000 gallons and <$50K/year in excise tax)
Annual option (small operations):
- Due January 15 (for operations with <20,000 gallons and annual federal excise tax filing)
Federal Excise Tax Return
Wine excise tax is tiered by alcohol content and wine type. As of 2026, rates per gallon are:
| Wine Type | Tax Rate |
|---|---|
| Still wine (≤14% ABV) | $1.07 |
| Still wine (>14% to <21% ABV) | $1.57 |
| Still wine (21% to 24% ABV) | $3.15 |
| Sparkling wine | $3.30–$3.40 |
Small producer credit: If you produce ≤150,000 gallons annually, you qualify for a $0.90/gallon credit on the first 100,000 gallons removed. For production >150,000 but ≤250,000 gallons, the credit phases down by 1% per 1,000 gallons over 150,000.
The larger CBMA (Craft Beverage Modernization Act) credit allows up to 750,000 gallons of credit-eligible wine per year for small producers.
Record Retention: The Three-Year Rule
This includes:
- All cellar records (crush, fermentation, treatment, blending, bottling)
- Inventory worksheets and adjustments
- Purchase invoices and sales documentation
- Source documents supporting your records
If the TTB officer conducting an audit determines it necessary, they can require an additional 3 years of retention on top of that.
Digital records stored on cards, tapes, discs, or databases must be retrievable within 5 business days.
Five Audit Triggers (And How to Avoid Them)
1. Late or missing Form 5120.17
- Late filing triggers penalties and interest. Set calendar alerts for the 15th.
2. Inventory shrinkage you can't explain
- Physical count doesn't match your records. Evaporation, breakage, sampling must all be logged as losses.
- Phantom gains suggest unreported purchase or transfer.
3. Cellar treatment gaps
- Every addition to wine (including water, juice, spirits, fining agents) must be documented.
- Undocumented treatment makes label claims (varietal purity, vintage claims) unverifiable.
4. AVA documentation failures
- To claim an appellation on your label, you must prove 85% (or 100%, depending on AVA) of grapes came from that region.
- Keep grape receipts by vineyard/source.
5. Blending without paperwork
- Multi-component blends require written blend records showing each component's origin, volume, and lot.
How Cepaos Simplifies TTB Compliance
Cepaos is built to eliminate compliance friction. As you run your winery, compliance records accumulate automatically:
- Crush-to-bottle lineage: Every grape receipt, fermentation step, treatment, and blend is logged in one place.
- Inventory reconciliation: Wine movements (production, transfers, sales, losses) auto-calculate inventory balances by type.
- Form 5120.17 data: Monthly report data is generated directly from your recorded operations. No manual spreadsheet reconciliation.
- AVA and blend tracking: Grape source and blend composition are indexed from day one, ready for audits.
- Retention audit trail: All records timestamped and retained per TTB timelines.
Compliance isn't a separate function. It's a byproduct of detailed operational record-keeping.
Your cellar records are your defense. Build them as you operate, not three days before an audit.
Sources
- TTB Form 5120.17 Guide
- 27 CFR Part 24: Wine Regulations
- 27 CFR 24.278: Tax Credit for Small Domestic Producers
- TTB Quick Reference Guide to Wine Excise Tax
- TTB Filing Due Dates for Operational Reports
Related articles
- AVA Compliance: Navigating US Wine Appellation Requirements
- TTB Compliance Guide: What Every US Winery Needs to Know
- Wine Traceability in the US: TTB Compliance and What Wineries Need in 2026
- DTC Shipping Compliance: State-by-State Requirements in 2026
- Harvest Management for US Wineries: Grape Reception and Traceability