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Winery Expansion? What TTB Needs from you!

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Blog 22

Your winery business is great and you’re expanding -don’t forget to amend your basic permit with TTB.

Demand for your wine seems to be going nowhere but up!  That’s fantastic, but you are having to deal with increased production issues.  Perhaps you have bottled all you can from your vineyard and you are having to source grapes. Local interest in your winery has caused that small tasting room you created when you opened your winery to now be woefully inadequate to handle the growing stream of individuals that seem to be more and more interested in your wine.

You have worked hard to preserve the quality of your wine and clearly want to provide for customer demand.  Countless hours are spent to determine how you can expand your facilities to accommodate growth.  It seems like everything will need to be expanded or reconfigured – from equipment and other production rooms, bottling and labeling areas, cellar space and tasting rooms.  You have likely figured out your logistics with an architect, a general contractor and an interior designer.

Your architect and builder are likely going to be well aware of permits and licenses needed by local governments for your expansion.  What may not seem obvious is that you need to notify TTB of the need to amend your basic permit.  While it is logical to think that once you have a winery permit you never need to amend it, it is also logical to think that if something changes, you need to amend the permit.  No different than the architect and builder getting a new permit from your local government to add onto, or remodel  your existing winery buildings, you need to amend your basic permit when you alter those premises.

Think back to when you were completing Form 5120.25 – Application to Establish and Operate Wine Premises.  Remember how detailed the description of your winery buildings had to be?  The application calls for you to describe each wine premises building as to size, construction, and use. The Federal Regulations associated with this requirement indicate that the “description will clearly indicate any area of the wine premises used as bonded wine premises, used as taxpaid wine premises, or alternated for use as bonded wine premises and taxpaid wine premises. The means employed to afford security and protect the revenue will be described. If required by the appropriate TTB officer to segregate operations within the premises, the manner by which the operations are segregated will be described.”

If any of the above descriptions change, because of changes to doors, walls or other infrastructure, you need to amend your basic permit.  This amendment must be submitted within 30 days of the change in premises, and the submission must make the initial application file accurate and current. Failure to abide by these requirements, like all violations of alcohol laws, creates the possibility of fines or incarceration.  Of course, perhaps the most daunting punishment is loss of your permit to produce.  If you have any questions regarding expansion of your winery and compliance with the regulatory authorities, please don’t hesitate to contact us.

We're Here to Help

Dear friends in the alcoholic beverage industry,

As we as an industry, nation and planet collectively try to navigate this unprecedented period the coronavirus has brought us, We’d like you to know that we at Craft Beverage Consultants (the other CBC!) are here to answer any question you may have (or not know you have) about not just surviving this time but positioning yourself to thrive as soon as social distancing measures allow your business to function at full capacity again.

If you schedule a free 60-minute phone or video conferencing consultation with me or any of my 11 highly specialized colleagues, we’ll help you figure out any of your immediate and/or longterm business needs, or “everything but the staffing,” as we like to say. We’re not high-pressure sales kind of people, especially these days, so you don’t have to worry about fending off annoying pitches. Make an appointment on our website or Facebook page, or just call us the old-fashioned way at 314-768-0220.

Our experts have a combined 150 years in the alcoholic beverage industry, with deep knowledge in everything from sales and distribution, production, and regulatory compliance to marketing, package design, event planning, IT, (social) media, hospitality, and even values-based executive coaching. 

For example, we can coach you through this season when chain accounts have canceled their spring, in some cases, fall resets and distributors have drastically cut orders. Our director of business strategy and compliance can save you money – now – on excise taxes, caution you to avoid naming your beers in ways that risk alienating your buyers (Wuhan Wheat? Coronavirus Cream Ale? Groan. No.), and secure TTB approval for the tastefully named beers you do make. Our creative director and web team can get your e-commerce site up and running and launch a social media campaign that keeps you top of mind for current and future customers. Our director of storytelling can put you in front of the press so you can tell your story to your community. 

Once you’re ready, we can look forward together. Now is the time to talk about post-virus. We all suspect the legal landscape to look different. But how? And how do you prepare yourself in a way that positions you to charge out of the gate ready to maximize the potential and profit of whatever the “new normal” turns out to be? Please get in touch so we can talk about it. 

CBC’s roster includes local and regional clients like Epic Brewing, Logboat Brewing, Piney River Brewing, SudWerk Brewing, Waves Cider and Common Cider Company, just to name a few.  The agency was founded in 2004 by Jacob and Beth Halls, formerly known as Convergence Consulting; Rick Laxague, joined as a partner in charge of sales, marketing and distribution consulting in 2019. 

Rick hase close to 20 years of experience, a bulk of which was with Crescent Crown Distributing in Arizona. His last role there was Area Sales Manager for the dedicated craft beer division, coaching and leading a sales team to be nationally recognized. In early 2014 Rick helped take a regional brewery national as their Director of National Accounts and increase that segment of their business from 30,000 cases to almost 300,000 cases in two years, an increase that equates to $4.8 million in IRI dollar sales. 

Co-founder Jacob Halls brings 17 years of experience in regulatory compliance, business strategy, marketing and craft brand management to the company. In his former position as craft brand manager for the N.H. Scheppers Distributing Company in Columbia, Missouri, Jacob helped lead his team to winning the 2016 Distributor of the Year award from New Belgium and to a nomination for the Brewers Association’s Distributor of the Year award. Jacob is also the founder and director of the South East Craft Beer Fest and several other industry specific charitable event marketing festivities. Beth Halls is Director of Business Operations and Coordinator of Charity Operations for the festivals and events run by CBC, such as the South East Craft Beer Fest, MO Bacon & Bourbon, and many more. 

Again, please reach out to us for anything.  CBC can be reached at (314) 768-0220 or at craftbeverageconsultants.com.

We look forward to meeting/talking soon.

Sincerely,

Rick Laxague, Jacob Halls, and Beth Halls