Winery compliance is a cumbersome yet necessary part of running a winery and filing the TTB report is a critical component of it. If you don’t get it right, it can lead to legal headaches down the line. Luckily, Ann Reynolds, owner of Wine Compliance Alliance, joined Expert Talks to share her wisdom and help wineries sidestep the most common mistakes made when filing this report. View the video below or read on to see if you’re making any of these mistakes and learn how to avoid them in the future.
Mistake #1: Signed by Someone Without Authority
Let’s start with a facepalm-worthy error: having the wrong person sign your report. The TTB isn’t a fan of unauthorized autographs.
Why This Happens: Sometimes, wineries assume that any team member can sign off on compliance reports. Spoiler alert: they can’t.
How to Avoid It: Make sure the signer has:
- Power of Attorney (think winemakers, controllers, or other trusted folks).
- Filed a Signing Authority Form (typically for owners or managers).
Pro Tip: Pay.gov streamlines the process and reduces errors. Plus, it saves trees—win-win!
Mistake #2: Not Filing as Often as Required
Do you know the thresholds for how often you should be filing your TTB report? Your filing frequency depends on your in-bond gallons and the amount of taxes you owe to the TTB at a given time.
Why This Happens: You may have wine in-bond that exceeds the limit without knowing due to poor tracking or large purchases of bulk wine. This highlights the need for a strong tracking system so you know what you have and exactly how much of it.
How to Avoid It:
To determine how often you need to file, double-check your gallons in bond. Also, keep in mind how much excise tax you owe to the TTB. To qualify for annual filing – you can’t owe more than $1,000 in excise taxes and have more than 20,000 gallons in bond. Quarterly cut-offs are 60,000-20,000 gallons in-bond and owe less than $50,000 in excise taxes. Finally, a winery with over 60,000 gallons in-bond is required to file monthly.
- Annually: Less than 20,000 gallons + less than $1,000 owed in excise taxes.
- Quarterly: 20,000–60,000 gallons + less than $50,000 owed in excise taxes.
- Monthly: Over 60,000 gallons.
Keep an eye on your inventory, in tank, in barrels, and bottled in-bond to stay on schedule. Take a look at your previously filed report, or use a robust tracking system to manage your wine inventory to stay compliant.
Mistake #3: Ignoring Amended Reports
Mistakes happen. But pretending they didn’t? That’s a recipe for disaster. This is why amended reports exist, and are necessary to submit as soon as you realize that something is off.
When Would You Need To Do This: If you file your report and discover that you forgot to bottle a wine, something not included that should have been included, or the numbers that went into that report were off.
Why This Happens: Forgetting to update past reports when correcting errors is an all-too-common oversight. Communication across teams using paper-based reporting can lead to more mistakes and rework.
How to Avoid It:
- If you mess up, file an amended report ASAP.
- Fixing errors like incorrect gallons or mismatched numbers now saves headaches later and keeps your reports in balance.
Pro Tip: Think of amended reports as the Band-Aids of winery compliance—essential for quick fixes and super easy to do when filing on pay.gov!
Mistake #4: Beginning On-Hand Numbers Don’t Match Ending Numbers
If your inventory doesn’t match up from one report to the next, the TTB will notice. And this will most definitely start raising some red flags.
Why This Happens: Poor record keeping or overlooking carryover numbers can create a mismatch.
How to Avoid It:
- Double-check that the ending numbers on one report match the beginning numbers on the next.
- If they don’t, file an amended report (see Mistake #3).
Pro Tip: Consistency is your best friend here—The next time you file have your old report pulled up so you can copy the exact numbers.
Mistake #5: Gallons on Line 2 Don’t Match Section 4
Listing gallons produced by fermentation without matching materials received and used in Section 4 is a big no-no to the TTB, although it may seem counterintuitive to some. Think of this as your bulk weight to volume – you can’t make wine out of nothing!
Why This Happens: Misunderstanding how materials received and produced by fermentation are defined or thinking you are somehow double counting the volume.
How to Avoid It:
- Use tools like InnoVint to track production and materials accurately.
- Ensure everything is accounted for – Section 4 should only be used during harvest season, and it influences line 2 directly
Accurate reporting here saves you from unnecessary scrutiny, as this is one of the top contenders for inaccurate reports.
Mistake #6: Submitting an Out-of-Balance Report
Submitting a report where the numbers don’t add up is a surefire way to get flagged. Pay.gov won’t even let you submit if it’s out of balance.
Why This Happens: Misaligned or missing data from your transactions can create an imbalance. Gains and losses are the most common reason this happens. A missed work order or losses not recorded can lead to this.
How to Avoid It:
- Use Pay.gov to catch errors before submission.
- If flagged, retrace your steps to find and fix the issue.
- Massaging the numbers when estimating losses will allow you to get to a balanced state
Pro Tip: Filing regularly (monthly or quarterly) keeps things manageable and reduces the risk of mistakes.
Final Thoughts
Avoiding these six mistakes will take the headache out of your monthly, quarterly, or annual reporting. As Ann Reynolds points out, a winery operating system like InnoVint and consistent record-keeping make compliance much smoother. If you’re feeling stuck, Ann offers Zoom check-ins, checklists, and webinars to get you back on track. Check out her website here.
Want more content like this? View the rest of the Expert Talks series on The Punchdown, InnoVint’s free online space for winemaking professionals. You can contact Ann directly on The Punchdown, and connect with colleagues throughout the industry. If you’re not a member, it’s free to join here.
Helpful Links:
Watch all the Expert Talks on The Punchdown
Learn more about Wine Compliance Alliance
Access the TTB 5120.17 Form