How to Export Wine and Spirits: TTB Permits, Taxes & AES

Exporting wine and spirits from the United States turns on three things: the right TTB credential, the right federal excise tax treatment, and the destination country’s import paperwork. There is no standalone “export permit” — a winery, distillery, or brewery operating under its existing TTB qualification can export its own product, but anyone else in the business of buying taxpaid wine or spirits for export must first obtain a wholesaler’s basic permit under the Federal Alcohol Administration Act. Get the tax treatment right and the federal excise tax never has to be a cost: product can leave bonded premises without payment of tax, or you can claim drawback of tax already paid, under 27 CFR Part 28.

This guide walks through the five steps — TTB qualification, the tax path, labeling, destination-country certificates, and the AES filing — plus the state-law and FDA details that trip up first-time alcohol exporters.

Step 1: Confirm Your TTB Qualification (or Get a Wholesaler’s Basic Permit)

Your TTB starting point depends on who you are in the supply chain. Proprietors of a distilled spirits plant (DSP), bonded wine cellar or bonded winery, or brewery can export the products they produce under their existing TTB qualification. Everyone else — trading companies, brand owners who don’t hold production premises, export intermediaries buying taxpaid product for resale abroad — must file TTB Form 5100.24 and obtain a basic permit as a wholesaler before commencing business, because the FAA Act requires a permit to purchase alcohol beverages for resale at wholesale in interstate or foreign commerce. Applications go through TTB’s Permits Online system, and there is no federal fee.

Edge cases exist — one-off transactions, brokers who never take title, export-only arrangements — and the permit analysis can shift with the structure of the deal. If your situation doesn’t fit a row in the table cleanly, confirm your status with TTB or counsel before you ship rather than after.

Step 2: Choose Your Federal Excise Tax Path — Export in Bond or Drawback

Federal excise tax should not be a cost of exported product, and 27 CFR Part 28 gives you two routes to make sure it isn’t. Export in bond (without payment of tax): wine and spirits can be withdrawn from bonded premises for export without the excise tax ever being paid, provided the regulatory removal, shipment, and documentation requirements are met. Drawback: if the tax has already been paid or determined — typical when an exporter buys taxpaid bottled product — TTB allows a drawback claim equal to the tax paid once you submit the required evidence of exportation.

Either way, proof of export is the whole game. Keep the bill of lading and export documentation; a missing export record converts a tax-free shipment into a tax liability.

Step 3: Sort Out Labels — the COLA Export Exemption and Destination Rules

Product bottled for export in bond does not need a TTB Certificate of Label Approval. The COLA requirement attaches to wine and spirits bottled for the U.S. market; a bottler withdrawing wine without payment of tax for exportation in bond is not required to obtain a COLA before bottling. What replaces it is harder: the destination country’s label rules — language, mandatory statements, health warnings, importer details, and in a number of markets formal label registration or pre-approval before the first container clears. Your importer should drive this, but verify independently and get label sign-off before the bottling run. For the general framework of who owns label compliance in an export transaction, see our guide to export labeling requirements.

One FDA note: U.S. wineries and distilleries are food facilities and must hold a current FDA food facility registration (renewed biennially). It’s a domestic obligation, but foreign importers and regulators sometimes ask for evidence of your U.S. regulatory standing, so keep the registration current and the number handy.

Step 4: Get the Destination Country’s Certificates and Import Requirements

Most destination countries require certificates with the shipment, and TTB issues them. Through the myTTB electronic export certificate system, exporters can generate certificates of free sale, health/sanitation, origin, age, and authenticity, depending on what the destination demands. The pattern varies by market: China accepts a consolidated wine export certificate combining origin, health/sanitation, and authenticity/free-sale in one document; Hong Kong and Taiwan use the APEC model wine certificate; the EU requires a simplified export certificate or VI-1 form for U.S. wine. Beyond certificates, confirm with your importer what they need on their side — an import license for alcohol, label registration, and any restrictions on alcohol content or container sizes. The importer of record abroad owns those legally, but your shipment sits in customs if they get it wrong.

Step 5: File EEI in AES When Required and Keep Proof of Export

Electronic Export Information must be filed in the Automated Export System when the value of goods under a single Schedule B number, shipped from one U.S. principal party in interest to one consignee on one conveyance, exceeds $2,500 — or at any value if an export license is required. Shipments to Canada are exempt at any value (annotate documents “NO EEI 30.36”), with exceptions for licensed goods and shipments moving through Canada to a third country. The AES Internal Transaction Number goes on your shipping documents, and the export record doubles as part of your evidence for the tax-free or drawback treatment in Step 2.

State Rules Still Apply

Your state license governs your business even when the customer is overseas. State alcohol codes control where you can warehouse product, what your license class lets you sell and to whom, and what records you keep — and a handful of states regulate export sales activity more closely than others. Exporting doesn’t exempt you from your home state’s three-tier rules; check your license conditions before adding an export channel.

Frequently Asked Questions

Do I need a TTB permit to export wine or spirits?

If you’re the TTB-qualified producer (winery, DSP, brewery), your existing qualification covers exporting your own product — no separate export permit exists. If you’re buying taxpaid product to resell abroad, you need a wholesaler’s basic permit under the FAA Act before commencing business.

Do I pay federal excise tax on exported wine and spirits?

No, if you follow 27 CFR Part 28: ship in bond without payment of tax from bonded premises, or claim drawback of tax already paid once you submit proof of exportation. Without proof of export, the tax sticks.

Does exported wine need a COLA?

Wine bottled and withdrawn without payment of tax for export in bond doesn’t require a COLA. The destination country’s labeling and registration rules apply instead — and they are often stricter.

When do I file AES for an alcohol shipment?

When any Schedule B line in the shipment exceeds $2,500 to one consignee, or whenever an export license is required. Canada-bound shipments are generally exempt.

Reidel Law Firm advises wineries, distilleries, and beverage exporters on TTB, export, and trade compliance — on flat fees, so the legal budget is fixed before the work starts. Get a flat-fee compliance memo mapping the permits, tax treatment, and filings for your export program.