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TTB HELPASK ME ANYTHING: ABOUT TTB REPORTINGDo you have a question about TTB Reporting? Ask Me Anything! Submit a question here at the ADI Webpage and Donald Snyder of Whiskey
Resources LLC will publish the questions and his responses on-line. Even though posted questions will not show the asker, please avoid asking or
sharing anything confidential or incriminating as the question may be posted online for all to see.
Q: My DSP gets wine in from an adjacent Bonded Winery for distillation. How do I report receiving and using that?Q: My DSP gets wine in from an adjacent Bonded Winery for distillation. How do I report receiving and using that?
A:A: If the wine coming into your distillery will be used only for distillation, you only need to report the wine being used as a raw material or
fermentable on the Production Report Page 2, “Part 6 – Materials Used”. Most distilleries will put the number of gallons of wine distilled on “Line
9. Grapes” or on “Line 10” and manually write “Wine”. Bringing in wine for distillation does not require a Transfer in Bond. The resulting distilled
brandy or spirits are reported as normal on the Production, Storage, and/or Processing reports. Make sure you keep local copies of your Bill of
Ladings or other Records of Receipt in the event of an audit.
Q: How do I track or report Heads and Tails?Q: How do I track or report Heads and Tails?
A:A: Records of heads and tails production, re-distillation, or destruction are for internal use only kept locally at the distillery. If you don’t re-use or
re-distill heads and tails, make sure you are disposing of the spirits and recording the destruction locally in a way that is compliant with your
local regulations. Heads and tails are considered Unfinished Spirits and are only reported to the TTB on the Production Report each Quarter on
“Line 17 b. Unfinished Spirits” if you have a tank with heads or tails left over in a Production Tank at the end of the quarter. Most distilleries will
physically do something with the heads and tails after each run and not leave any balance of or report Unfinished Spirits at the end of the
Quarter.
Q:Q: What TTB reports does a craft distiller have to file and when?What TTB reports does a craft distiller have to file and when?
A:A: Distillers making Beverage Alcohol only (no industrial or denatured spirits) must file monthly operations reports including a Production Report
(F5110.40), Storage Report (F5110.11), and Processing Report (F5110.28) due by the 14thof the next month. In addition, distillers must file and pay
a Federal Excise Tax (FET) Return (F5000.24) after every tax period.
Q:Q: How and when do craft distillers have to pay taxes?How and when do craft distillers have to pay taxes?
A:A: Most craft distillers pay $13.50/proof gallon for any cases of beverage alcohol they remove from the bonded distillery space including cases
they move to their gift shop or tasting room areas. For a craft distillery who pays less than $50,000 in excise tax per year (or ~3,700 six pack cases
per year), they can pay every quarter (4 times per year). If a distillery pays more than $50,000/year in one calendar year, they must pay every 15
days and 3 times in September.
Q:Q: What do I do if I have to destroy bad spirits or finished cases?What do I do if I have to destroy bad spirits or finished cases?
A:A: If you need to destroy alcohol still in-bond due to contamination or some other issue, complete an internal Record of Destruction (see 27 CFR
19.459 for specifics on what exactly needs to be recorded). This record should be kept internally in the event of an audit and should not be
mailed to the TTB with your monthly reports.
Q:Q: What is the difference between a Gallon, a Wine Gallon, and a Proof Gallon?What is the difference between a Gallon, a Wine Gallon, and a Proof Gallon?
A:A: When distillers talk about a Gallon, they traditionally are referring to a volumetric measurement of liquid without any regard to proof or %
alcohol. For example, a milk jug has 1 Gallon of liquid. This is also referred to as a “Wine Gallon” as winery operations and taxation is based on
the volume of gallons of wine. A Proof Gallon is a universal measure of the amount of alcohol inside that gallon. Proof Gallons are measured by
the Wine Gallons (corrected for volume expansion of alcohol to 60 degrees F) times the Proof/100. For example, if a 1 gallon milk jug had 150 proof
spirits (or 75% ABV), it would have 1 Wine Gallon or 1.5 Proof Gallons of alcohol. A 1 gallon milk jug with 50 proof spirits (or 25% ABV) has 1 Wine
Gallon or 0.5 Proof Gallons. A 50 gallon tank holding 80 proof spirits (or 40% ABV) would have 40 Proof Gallons.
Q: I’m trying to export my production into the US. Is there is a minimum of content for the alcoholic beverages in order toQ: I’m trying to export my production into the US. Is there is a minimum of content for the alcoholic beverages in order to
sell in the US?sell in the US?
A:A: There is no minimum bottling proof in order to import and sell distilled spirits into the US. The easiest and best approach is to contact the TTB
directly to have the product reviewed and classified with a Pre-Import Evaluation. The TTB will help classify the spirit and will let you know if it
requires a formula or if there are any specific issues with importing the product. They may require a sample. Check out the International Affairs
page at TTB.gov for more information.
Q: Can a distillery be in the same building that may have some residential units? Not an apartment complex but in a multi-Q: Can a distillery be in the same building that may have some residential units? Not an apartment complex but in a multi-
floor mixed used building that may have some loft apartments?floor mixed used building that may have some loft apartments?
A:A: This is very tricky and is the source of much debate. Here is the exact regulation: “Subpart F – Location and Use (of distilleries) § 19.131
Restrictions as to locations. Distilled spirits plants shall not be located in any dwelling house, or in any shed, yard, or enclosure connected with
any dwelling house, or on board any vessel or boat, or on premises where beer or wine is produced, or liquors of any description are retailed, or
(except as provided in §19.133) on premises where any other business is conducted.” In my personal interpretation, if the distillery is physically
connected to one of the loft apartments, it may not be approved. You may also run into local or county fire or zoning regulations that may
prohibit the distillery in the building. I highly encourage you to reach out to the TTB directly to have a conversation about the specifics of your
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potential distillery space before you submit your DSP Application and wait the 120 days for review only to get rejected. Here is some relevant ADI
Forum Discussion on the subject.
Ask me Anything About TTB Reporting
Important DisclaimerImportant Disclaimer: The content above has been provided by Donald SnyderDonald Snyder, Whiskey Resources LLC, and Whiskey Systems Online and are
not affiliated with the TTB and answers posted are only from personal experience and personal understanding of the Federal Regulations.
Individual distilleries and owners are ultimately responsible for ensuring all actions taken are compliant and follow TTB and other Federal
Regulations. Advice and links posted on this site should be used at your own discretion. Donald Snyder, Whiskey Resources LLC, and Whiskey
Systems Online will not be held liable for any damages resulting from advice, responses, or answers posted on this page.
NATIONAL REVENUE CENTERFor Permit Applications and Tax Filings…TTBFor Permit Applications and Tax Filings…TTB
Customer Service Desk 887-TTB-FAQS (877-882-3277)Customer Service Desk 887-TTB-FAQS (877-882-3277)
(8:00 am – 5:00 pm EST)
or by email: [email protected]
Permits Online email: [email protected]
Advertising, Labeling and Formulation DivisionAdvertising, Labeling and Formulation Division
Alcohol and Tobacco Tax and Trade Bureau
Advertising, Labeling and Formulation Division
1310 G Street NW, Box 12
Washington, DC 20005
Customer Service Desk 202-453-2250 or 866-927-ALFD (2533)Customer Service Desk 202-453-2250 or 866-927-ALFD (2533)
Fax: (202) 453-2984
(8:00 am – 4:30 pm EST)
or by email: [email protected]
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TTB PROOFING VIDEO SERIES:TTB PROOFING VIDEO SERIES:Introduction to Proofing Video Series (4:09) – TTB’s Beverage Alcohol Laboratory offers a proofing video series to walk you through several
frequently used procedures to proof distilled spirits correctly.
Part 1 – Proofing Spirits with a Hydrometer (4:29) – Learn how to proof spirits using a hydrometer; this technique is cost effective and accurate.
Part 2 – Proofing Spirits with a Densitometer (3:19) – Learn how to proof spirits using a densitometer; this technique is fast and can be automated.
Part 3 – Distilling Spirits for Proofing (4:54) – High solid spirits must be distilled before proofing. Learn how to distill samples using a small
laboratory distillation unit.
Part 4 – Determining Proof Obscuration by Evaporation (3:08) – Dissolved solids may obscure the true proof of a sample. Learn how to determine
proof obscuration using the evaporation method.
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