Today, DTC Wine Workshops is featuring a guest blog post provided by Jenni Linteo, latest member of the DTC Consultant Network. Jenni supports small to mid-sized wineries in the areas of direct wine compliance, direct wine licensing and reporting. We hope that you find the information shared to be informative and useful. Enjoy!
Last week, as I was waiting patiently for the Game of Thrones season six premiere, I couldn’t help but think: Harvest is coming. As a winemaker or winery, you do not need the added stress of license changes, COLAs, and DTC state shipping licensing and reporting hanging over your head during harvest. Here are some compliance tips that you can implement throughout the spring and summer before the craziness of harvest begins.
Don’t put the cart before the horse.
If you need a new or amended licensing with the ABC and/or TTB, a new COLA, or direct to consumer shipping licensing, start now! Budget cuts have left the TTB horribly understaffed and processing times for licensing and COLAs are increasing every week. Also, get your COLA before you label your bottles. I have seen the TTB reject a label because a word was missing in the government warning on a label that was already on 500 cases of wine. That was a bummer – soaking the back labels off of 6,000 bottles of wine not only took a huge amount of time, but a lot of money.
Patience is a virtue.
If you start working on your compliance issues early, this one is easy. With increasing processing times, waiting for your licensing and COLAs can be as slow as watching paint dry on a humid day. I have a pretty good rapport with my contacts at the TTB and California ABC and every now and then I ask if an application can be expedited. There is an awkward silence then we both burst out laughing. Hey, it never hurts to ask. Individual state DTC licensing can take a bit of time too, so allow adequate time to obtain licensing before you start shipping to individual states.
Know your limitations.
As we all know, everyone has their own particular skill set. If you ask me about brix, yeast levels, or blending, my eyes will glaze over and I might start talking about the weather, Vintage High School girls’ soccer, or my dogs. However, ask me about TTB and ABC licensing paperwork, or DTC shipping licensing/reporting requirements for specific states, and I light up like Las Vegas on New Year’s Eve. I admit it – I love paperwork, following procedures, laws and regulations and yes, talking to the happy folks at the state and federal alcohol agencies. Most people when hearing this either get a worried look on their face, giggle awkwardly or look at me in sheer amazement and say “really?” Strange I know, but it’s what I’m good at and as any life coach will tell you, find your passion. Paperwork and regulations it is!!! My job has its perks too; I love introducing my friends to wines made by my clients and being a part (the administrative part) of the success of my clients.
The bottom line is, if you have the resources to hire a full-time compliance officer, that is fantastic! However, most small to mid-size wineries are better off hiring an independent compliance consultant to oversee their federal and state licensing, DTC shipping licensing/ reporting, COLAs, etc. Most compliance consultants are willing to work with you, either charging by the hour, preparing a flat-fee package on a project by project basis, and/or a monthly flat fee for state reporting on DTC shipping. I get a lot of satisfaction by alleviating the stress of compliance so that winemakers can focus on what they love: making delicious wine so consumers like me can, well, consume it.
Cheers!
Jenni Linteo
First Glass Wine Compliance
www.firstglasswinecompliance.com
[email protected]
415.450.0886