Untangling the complex world of wine direct shipping and compliance
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    TTB Expo 2008

    June 17th, 2008
    By Jeff Carroll - VP of Compliance, ShipCompliant

    The ShipCompliant research team is attending the first annual TTB Expo at the Northern Kentucky Convention Center, just outside of Cincinnati, today and tomorrow. The turnout here is quite impressive. In the opening remarks, the TTB team said their original goal was to get about 300 attendees from across the country. They had over 650 pre-register, and it seems like the actual attendance today is more like 1,000.

    The turnout from the wine industry is equally impressive. We’ve run into a number of friends and partners in the industry from across the country today.

    John J. Manfreda, Administrator of the Alcohol and Tobacco Tax and Trade Bureau (TTB), gave an excellent keynote address this morning, stressing an open dialog between the TTB and key industry stakeholders. They seem genuinely committed to listening to the industry to improve the ease of compliance with TTB regulations. If you have any questions or topics that you would like to get answers to while we are here, please feel free to leave a comment on this post or to drop us a private email at blog (at) shipcompliant (dot) com.

    4 Responses to “TTB Expo 2008”

    1. As more and more wineries are using mobile osmotic transport firms to come on to their bonded wineries to “de alc” wine in order to be able to keep the “estate” claim on the label and to save the transport of bulk wine back and forth to the “de alc” facilities, we’re required to go through the entire application process for a full fledged distilled spirits plant, both with the TTB and the state ABC offices. All of this to have the mobile companies come in for a few days each time, three or four times a year.

      I know you mainly deal with direct shipping issues, but thought I’d throw this out if someone wants to ask the question on our behalf about having an “abbreviated” or “limited use” DSP license and application process for this new situation.

      Thanks for your efforts to keep us informed – even though when I get your email in my in box, it usually prompts the thought “WHAT NOW?”

    2. Kimberly says:

      Great news, I guess…..

      We all know that the TTB is working with “key industry stakeholders”, but it’s in the best interest of large groups to keep the current systems in place. So what about the little guys who don’t benefit from the same things that the big guys do? So my questions is: what is the TTB doing to ensure the success of smaller winieries and wine-centric businesses in the ever-growing DTC segment of the market?

    3. Wineries using reverse osmosis (RO) units to remove alcohol from wine are required to qualify as a Distilled Spirits Plant (DSP) to conduct this operation on their premises. Indeed, as compliance consultants filing these applications for wineries, we understand and sympathize with the effort it takes to add these approvals to conduct this activity, which is often done infrequently.

      In response to your post, we spoke today with the TTB Technical Advisor and a TTB attorney about the idea of a simplified process for wineries to secure approval for de-alcoholization of wines on the winery premises. On both the Federal and the State level, the use of RO equipment is considered to be distillation. While it may seem simple for TTB to amend the winery regulations to permit this process, the Federal laws governing the distilling of alcohol do not give TTB discretion to allow distilling on a winery premise. The law requires the establishment of a DSP either adjoining or alternating with the winery premises. Unfortunately, the law does not allow TTB to implement your suggestion.

      The solution would be to have winery trade organizations request that Congress amend the Federal Alcohol Administration Act to allow this process on a winery premises without establishing a DSP. It is likely that the states would follow any change in Federal regulations on this matter.

      Alex Heckathorn & Jay McPherson
      Compliance Service of America

    4. Philip James says:

      Very interesting – Id never heard of a government body holding a trade show. Nice to hear that they are communicating with those with a vested interest in the industry.

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