LEX VINI

Can I Store Unlabeled Wine in Taxpaid Areas?

Many wineries wonder whether they can store unlabeled wine bottles or “shiners” (perhaps for aging or as library wines) in storage areas outside of their bonded premises.  The short answer from the “TTB” is no.  Although TTB regulations provide that wines must be labeled before they are removed for “consumption or sale,” the TTB has interpreted these regulations as meaning that wines must be labeled before they are removed from bond for any reason (although a few limited exceptions do exist).  Thus, shiners must either be stored within a winery’s bonded premises, or can be transferred via a bond-to-bond transfer to another bonded premises.  The TTB does permit appeals to this rule in extraordinary circumstances, although this would require a showing that storage at any bonded premises is impossible for some reason.  A simple “fix” to this solution would be expand your bonded wine premises area to include those storage areas where you would like to hold or age your unlabelled wine bottles.
For more information regarding the storage and transport of wines in bond, or for assistance in filing a bonded premises expansion to include storage areas, please contact Bahaneh Hobel at bhobel@dpf-law.com
Copyright Dickenson Peatman & Fogarty at www.lexvini.com

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