TTB and Me

Can I hear a HELL YEAH please?!

I opened my email this morning and saw something that made me very happy! An email from our compliance consultant.  After five months our basic permit from the TTB has been accepted.  

There are many hoops that you need to go through in order to be in the wine industry and the first one, the most important since all others can only occur after this one, is being recognized by the Alcohol and Tobacco Tax and Trade Bureau.  So what does this mean for us?  It means the federal government recognizes Dracaena Wines as a wine producer and blender. We are recognized as an alternating proprietorship.  In the TTB’s terminology, we fall under Industry Circular 2008-4: 

An alternating proprietor arrangement consists of two or more persons or entities taking turns using the same space and equipment to produce wine. In almost all situations, an existing proprietor-owner of a bonded wine premises agrees to rent space and equipment to a new proprietor. Such an agreement allows existing wineries to use excess capacity and gives new entrants to the wine business an opportunity to begin on a small scale without investing in equipment. The existing and new proprietors are sometimes informally referred to as “hosts” and “tenants,” respectively. In other situations, two or more persons make plans to establish independently operated bonded wine premises, mutually agreeing to alternate the use of space and equipment. In these latter arrangements, no proprietor functions as a “host” to the others because each has agreed to share responsibility more or less equally. The designation of one alternating proprietor as a “host” to the other(s) is not a TTB requirement and carries no responsibilities or privileges that differ from those of the other alternating proprietors.

In simple terms it means that we do not own a formal facility.  We rent space and equipment from another winery. As the federal government sees it Dracaena Wines now has a S*^%load of paperwork to file and maintain. We are now officially accountable for all aspects of the operations as a winery and our responsibilities include but are not limited to:

• Producing Wine and/or controlling and directing wine production operations
• Storing our wine in one area segregated from wine belonging to the host of any other tenant
• Keeping and being able to knowledgeably discuss appropriate winery records and reports with TTB representatives
• Labeling the wine with the appropriate name and address as applicable
• Obtaining COLAs as necessary
• Paying tax at the appropriate rate upon removal of the wine from the winery
• Overseeing quality control

Why am I so excited? As I said earlier, now the ball can really start rolling. Yes, we are now officially a winery, but more importantly it means that we can now go online and file our COLA (Certificate of Label Approval). Gosh the government loves their acronyms don’t they?  We can submit our label and the government will look at and analyze it with scrutiny and decide if we will be allowed to use it.  So keep your collective fingers crossed for us! 

Now that the federal government has recognized us, the next step is for the state of California Department of Alcoholic Beverage Control (ABC) to approve us to operate in the state of California.  Every state’s ABC has their own stipulations for what they allow and don’t allow. For example, here in Jersey (where we keep our day jobs) we would not be allowed to be a registered winery.  In order to be a winery in NJ, you must own 2 acres of vineyard. Interesting, isn’t it? Well, I think so.  

As George R.R. Martin states in The Mystery Knight, “Wine makes all things possible.” In this case it is allowing Mike and I to “Pursue our Passion.”

 ~Sláinte!