Becoming and staying compliant: what to record, when, and why the form asks

27 CFR 24.300, 24.309

RecordThe registry and bond numbers, the filing cadence, and every other bonded premises you move wine to or from, with its registry number.

WhenBefore the first return, and on the day any of them changes.

Why the form asksThe form's heading shows the premises and the period. Every figure below the heading is a total for that period, and the app sets the period from your cadence. A transfer identifies the other premises by its registry number, so the app won't record a transfer with a premises that doesn't have one.

27 CFR 24.301, 24.309

RecordProduction when the wine is gauged, never at the crush. A receipt in bond with the other premises, the containers and the class. A carry-in as an opening balance with its year, which isn't a movement, and each wine in it as a lot carried in, which doesn't post anything either.

WhenProduction on the day the wine is first measured: at the press for a wine fermented on its skins (red or white), or on the lot's gauge card once the ferment is done for a white or rosé pressed before it. A receipt on the day it arrived.

Why the form asksThe form's IN FERMENTERS line has its own instruction: "This figure is an estimate of material still fermenting at the end of the period... When fermentation is complete enter the specific amount produced in Part I Section A Line 2." So a lot crushed into a fermenter posts nothing until it's measured, and whatever is still fermenting at the end of a period goes on Part VII as an estimate.

Not a return.

RecordThe estimate for each lot in a fermenter, one entry at a time. It's either the calculation (the lot's tons times your house yield per ton for how it will be pressed), accepted or overridden, or the juice measured at a press before the ferment. An override more than twenty percent from the calculation needs a reason.

WhenAt the crush, again whenever the figure changes, and on the report before a return is filed, for the last day of the period.

Why the form asksPart VII of the form asks for it by kind of material (the footnote reads "State kind - apple, blackberry, etc.") and calls it an estimate of liquid. Fermata fills in a column for each fruit the fermenting lots are made from, headed with the fruit's name. Grape goes over column (a), as in TTB's own sample of the report. Fermata also fills in the TOTAL, which the blank form would otherwise leave at zero, lists anything it can't place, and locks the figures with the return. The fruit is recorded on each lot, never taken from the tax class, because the class can change while the fruit stays the same. A later change is shown beside the return as filed, one click away from the amendment.

27 CFR 24.301, 24.190, 24.310

RecordThe tax class on every movement, copied onto it the day it's recorded. A reclassification when a wine changes class, with the sparkling method if the new class is sparkling. A blend's class at both ends. And the kind of wine (its class and type as the label states it, such as red table wine or cider) on the lot's Class and type card. The kind of wine is copied onto every entry, and the app requires it on a taxpaid removal, a transfer in bond, a return to bond and a tasting entry, because 27 CFR 24.310, 24.309, 24.312 and 24.97 each ask for it.

WhenA reclassification on the day the class changed, at tirage or when fortifying took the wine past a bracket. A blend when it's pumped. A lot still in its fermenters also changes class on its Tax class card. Only the wine a press has put on the ledger moves in an entry. What's still fermenting takes the new class with the lot, and is produced in that class when it's gauged.

Why the form asksThe form's columns are the tax classes, and its own footnote on blending says to report it only where wines of different tax classes are blended together. A reclassification has no captioned line, so your standing decision on the reports page sets where its two sides go. The app flags a lot whose measured alcohol doesn't match its class, but never changes the class. It also flags an effervescent wine, or a still wine made as its base, measured over the 14 percent 27 CFR 24.190(b) sets for both.

27 CFR 24.306, 24.309, 24.310, 24.97

RecordA taxpaid removal with its channel. A transfer in bond with the other premises and the containers. A removal for distilling material or to a vinegar plant. Wine used for testing, used for tasting, or taken as samples. Family use, and wine destroyed. Used for tasting means wine carried to a tasting room on the bonded premises: one entry each time wine is taken in, with the date, the gallons and the kind of wine, not one per pour.

WhenOn the day it left, on the book it left from: bulk from a tank, cased from packaged wine. Wine for a bonded tasting room on the day it's carried in.

Why the form asksThe form separates USED FOR TESTING from USED FOR TASTING and has lines for distilling material and a vinegar plant. It has no captioned line for destroyed wine. The write-in lines offer DESTROYED in their own list, and putting a figure there is a standing decision you make. 27 CFR 24.97(b) keeps a tasting room's record as the date, quantity and kind of wine transferred to it, and 24.97(c) collects the tax on wine taken beyond what the tasting needs. 24.310 has taxpaid removals summarized by day and by tax class to the tenth of a gallon. Section B line 8 is the sum of that summary, with the difference from the removals cleared each period on a write-in line captioned OTHER. That's why a removal goes on the day it left. If the app doesn't place a kind of entry on a line, the working paper lists it with the reason, so it never shows as a blank that looks like zero.

27 CFR 24.312

RecordWine coming back to bond with its origin, the tax paid, the case marks, when it was packed and the evidence. And, as a separate later event, bottles emptied back into a tank.

WhenThe day it came back, and the day it was dumped, each as its own entry.

Why the form asksThe form reports a winery's own returning wine and wine bought taxpaid on one line, but treats them differently. So the entry records which it is when it's saved, because that can't be filled in later. The claim window is worked out from the return each time, never stored. What the winery did about a claim is recorded in its own words. The app doesn't calculate a claim amount and doesn't say whether you're eligible.

27 CFR 24.266, 24.268, 24.313

RecordA processing loss on every rack, filtration and measured top-up, with which move it was. A casualty loss with a sentence or two about what happened. Breakage of packaged wine. And the gains and losses a signed count posts for each lot on each book.

WhenA loss on the day it happened, as part of the move. The count's differences on the day of the count, posted when you sign it, never typed in by hand.

Why the form asksTTB's guidance for line 30 has the year's normal operational losses (topping, racking, evaporation, lees, bottling) reported when a complete physical inventory is taken. So the report holds each processing loss until a count is signed, then puts it on line 30 beside what the count found. The ledger still records each loss on the day it happens. A casualty goes on line 29 in the period it happened, and 27 CFR 24.268 also has it reported to the TTB officer immediately. That report is yours to make. The form shows one difference per column, so the app nets a lot that's up three against one that's down eleven, while the ledger keeps both. The count locks when signed, and its record prints from its own lines.

27 CFR 24.10, 24.255, 24.308

RecordPackaging with the size the wine went into, linked to its run. And on the run, the fill test and the alcohol determination.

WhenThe day the line ran. The fill test and the alcohol figure whenever each was done.

Why the form asksBOTTLED is a line on both sections, and 27 CFR 24.10 calls any container of four liters or less a bottle, whatever it's made of. So a can, a pouch or a small box counts as bottled on the form. A container over four liters isn't a bottle by that definition, and up to sixty liters it isn't a bulk container either. Fermata puts the wine packed into one on the same two lines, because TTB's guidance for those lines reads "bottled and packed". That's a reading from desk research, and the question is listed with the open questions at the end of this chapter. A container over sixty liters is a bulk container and the wine in it is bulk wine, so the app won't record packaging into one. The bottled-wine record asks for the fill test and the alcohol determination for the run. The app prints both beside the format's nominal size and doesn't judge either one, because the tolerance is set by the regulation.

27 CFR 24.80, 24.85, 24.198, 24.218, 24.303

RecordThe formula TTB approved on TTB F 5120.29, entered on Settings exactly as the approval shows it. And each batch, recorded as one measured step on the move screen under Make formula wine: the base wine used (measured before the flavoring goes in), each flavoring and its amount, the formula wine produced (measured after), its measured alcohol and class, and an explanation if the gain differs from what the liquids added.

WhenThe formula before the first batch. Each batch on the day it's made, from the vessel holding the base wine to the one the formula wine goes into. The first batch makes a new lot. Later batches can go into the lot already there under the same formula.

Why the form asksA special natural wine or an other wine is made only under an approved formula (27 CFR 24.80). 24.303 keeps, for each lot, the formula number, the volume of wine used, the volume produced, the gain or loss with an explanation of any unusual one, and the essences. The step saves two entries with the formula's number on each, one for the wine used leaving the base lot and one for the formula wine arriving in its own lot, and records the flavorings as additions. That way the gain is on the books the day it happened, rather than turning up at a count. 24.85 limits what an essence containing spirits may add, and the step points out where a batch goes past those limits without deciding anything. Formula wine is kept separate: it goes into an empty vessel or with its own formula's lot, and the blend screen won't blend it into standard wine (24.198, 24.218). On the report, the two entries go on Section A's write-in lines 10 and 25, FORMULA WINE PRODUCED and USED FOR FORMULA WINE, each captioned from the blank form's own list and placed by the software. Part IX counts what was produced, what left taxpaid and what's in bond, by the formula's class. A juice or concentrate on the shelf with its fruit stated gets a Part IV column with its receipts and uses. Both parts are filled in from your records and locked with the return.

27 CFR 24.302, 24.304, 24.305, 24.314, 24.315, 24.317, 24.318, 24.321

RecordNothing extra. The composition, the effervescent-wine record, the sweetening record, the chaptalization and amelioration record, and the sugar, acid and decolorizing records are all put together from the additions, readings and moves you've already recorded. Deliveries for the sugar and acid accounts are logged on the additives shelf.

WhenWhenever a lot's history is opened or printed. Each section is worked out at that moment, and an empty section explains what being empty means.

Why the form asksEach of those records is its own section of the regulations, and each is kept separate from the return. What the app can't know is explained in words on the line instead of shown as a figure: a concentrate's own Brix, the gallon equivalent against a limit, or which operation sugar added to a fermenting must was. Nothing is judged against a threshold.

27 CFR 24.300

RecordThe filing itself, with a copy of its figures and of the decisions it was made under. And each standing decision, with your name and the date.

WhenAt the end of each period your cadence sets. An amendment whenever a movement dated inside a filed period had to be recorded late, with its reason. Record every entry when it happens. 24.300(b) defers one posted from a record made at the time until the close of the third business day after the day it records. The report lists the ledger entries written later than that, and the working paper counts them.

Why the form asksThe form's totals are calculated from everything that moved, but a kind of entry with no line isn't printed in any cell. So the review sheet shows by how much a section falls short and lists every line left for you. A filed return is locked. An amendment has its own attestation and replaces the return without overwriting it.

27 CFR 24.323

RecordThe credit share the winery claims for each tier and year, and each excise return as filed: the date, the confirmation and the figure exactly as on the return.

WhenThe share before the first period you want the tax worked out for. The return within the number of days the paper shows after each period ends.

Why the form asksWhat left bond taxpaid is already on the cased book, by class, and 27 CFR 24.310 has it summarized by day to the tenth of a gallon. So the first half of the paper needs no rate: it adds up the daily figures, as line 8 does. The rates are stored with their source, who checked them and when. Once that check is a year old, the paper stops working out the tax, so it never shows a figure from rates that may be out of date.

27 CFR 24.300

RecordNothing extra. The app keeps what it holds, and the archive is your own copy.

WhenDownload the archive whenever you like, and before a closing period ends.

Why the form asksEach record is kept for at least three years from its own date or its last entry, whichever is later (27 CFR 24.300(d)). A TTB officer may require up to three years more. That duty belongs to the record and to the winery, and it outlives the account. Nothing counts down from the day an account closes, and nothing is scheduled to remove the books.

Not a return.

RecordEvery application with its products, the intervals from the container, where each interval came from, and the applicator's attestation.

WhenOn the day of the spray, before you plan the pick date around it.

Why the form asksThis isn't part of a return, and no section of the wine regulations asks for it. The pre-harvest interval decides when fruit can be picked, and the re-entry interval decides when people can go back into the rows. Every night the app checks the shelf against the EPA's label list and reads the current label. It compares the figures but never overwrites them, and keeps every figure with where it came from.

Every kind, and its line

The form’s own captions, from the same table the working paper is filled in from.

Open questions

These compliance questions are still open. Until they're settled, the app records what the form's own words describe and makes no claim about any of them.

1. Is sparkling wine a separate tax class on the return, and where does it go?
2. How does wine in tirage report while it is in bottle?
3. What are the current varietal, appellation and vintage thresholds — and do hybrids differ?
4. Taxpaid wine returned to bond
5. Fortified wine and spirits on a bonded wine premises
6. Who is responsible for PHI and REI being current?
7. Record retention — and whether records can ever be deleted
8. When is wine "produced" — and how is material still fermenting reported?
9. What does the excise return need from the record, and may the app carry the rates?
10. Where does wine packaged in containers over four liters go on the report?
11. Where do processing losses and casualty losses go on the report?
12. When does wine sold direct to consumers leave bond?
13. How is a grape wine with another fruit's juice added recorded and reported?
14. When a buyer changes their mind about wine just sold, is the sale undone or the wine returned?
15. A barrel of wine sold taxpaid
16. How does a winery coming from other records start its sugar and acid accounts?
17. How does a winery coming from other records start the record of wine already on its taxpaid premises?
18. May an interval copied from a winery's own spray log decide when fruit may be picked?
19. How does a count of the sugar and acid on hand reach the account when it differs from the balance?