Wine, spirits & TTB

Permit, label, formula

Before the first case ships, the importer needs a TTB basic permit issued to the entity that will be named on the entry. Then each product needs a Certificate of Label Approval, obtained through COLAs Online, and the label that arrives in the container has to match the one that was approved. Some changes are allowable revisions to an existing COLA and some require a new one, and the difference is not intuitive. We check the approved image against the supplier's current artwork before the goods load, because a mismatch found at the port is a relabelling operation.

Two further approvals catch people out. Distilled spirits containing flavouring, colouring or other treatment often need TTB formula approval before a COLA can issue. And several categories carry origin or age documentation requirements of their own: wine from the European Union needs certification of proper cellar treatment, and spirits sold under a protected designation such as Scotch whisky, Canadian whisky, Tequila or Cognac need the certificate of origin or age their rules require. None of these can be obtained after the vessel arrives.

Excise tax changed hands in 2023

This is the single most misunderstood thing in beverage alcohol importing. Since 1 January 2023, the reduced rates and credits under the Craft Beverage Modernization Act are no longer applied at the border. The importer pays the full federal excise rate to CBP at entry, then claims the benefit back from TTB as a refund through the CBMA importer claims system. For that claim to work, the foreign producer has to be registered with TTB and has to have assigned an allocation to your entity before the entry was filed.

The standard rates are $13.50 per proof gallon on distilled spirits, $1.07 per wine gallon on still wine up to 16 percent alcohol by volume, and $18.00 per barrel on beer. Budget the full rate at entry. Importers who plan cash flow around the reduced rate and then discover their producer never registered are the ones who call us in January.

Classification is arithmetic, not adjectives

The heading turns on what the product is and on numbers, not on how it is marketed: still or sparkling, alcohol by volume against the band breaks, container size, and for spirits the proof. Duty on wine is generally a specific rate per litre, so the litre count and the alcohol content on the invoice have to be right or the duty is wrong. Spirits duty and tax both run on proof gallons, which is liquid gallons multiplied by proof and divided by 100, and a product at 40 percent alcohol by volume is 80 proof. On two thousand cases, rounding the wrong way is real money in both directions.

We build the entry from the case configuration rather than from the invoice total, and we reconcile the litres and proof gallons before filing. If your supplier ships mixed pallets of different sizes and strengths under one line, that has to be split, and we would rather do it before the summary than after.

Bonded warehousing buys time

Duty and federal excise tax are not due while the goods sit in a bonded warehouse. They become due on withdrawal for consumption, and goods exported from the warehouse never pay US duty at all. Spirits can also be transferred in bond to a distilled spirits plant, which defers the tax further. When rates are moving, or when you are selling a container through slowly, that deferral is often worth more than the storage costs. See in-bond and bonded warehouse for how the movement itself is filed.

Tariff exposure in 2026

Beverage alcohol has been squarely in the middle of the tariff actions of the last two years. Rates on European wine and spirits in particular have been threatened, imposed, amended and litigated under more than one authority, and the position has changed inside a single shipping cycle more than once. We do not quote a rate from memory or from the last entry. We check the Chapter 99 position on the day the goods arrive, we tell you what it costs, and where the rate is genuinely in motion we will talk through whether entering the goods into a bonded warehouse and choosing the withdrawal date is worth doing.

States are not our filing, but they are your problem

Federal clearance gives you goods. It does not give you the right to sell them. Every state runs its own licensing and distribution regime, most on a three tier structure that requires you to sell through a licensed wholesaler, and several require brand registration before the first case moves. We clear the federal side and we will tell you honestly where the state line sits, but the state licence is yours to hold.

What we need from you

1. A signed customs power of attorney, your TTB basic permit number and an adequate bond.
2. The COLA for every product in the container, and the artwork actually printed on the bottles.
3. Commercial invoice and packing list broken out by product, container size, bottles per case, cases, alcohol by volume and vintage.
4. Formula approvals, cellar treatment certification or certificates of origin and age where the category requires them.
5. Your CBMA allocation from the foreign producer, if you intend to claim the reduced rate.
6. FDA facility registration for the producer, and FSVP details.