INTERNATIONAL TRADE LAW
How to Import Wine and Spirits Into the U.S.
Importing wine and spirits into the United States means clearing two federal agencies on top of Customs — the Alcohol and Tobacco Tax and Trade Bureau (TTB) and the FDA — plus paying federal excise tax. Alcohol is one of the most heavily regulated imports there is: you need a federal permit before you import, label approval before the goods can be released, and an FDA prior notice for every shipment because alcohol counts as “food.” This guide walks the requirements in the order you’ll encounter them. It’s a specialized case of the general import process, with alcohol-specific layers.
1. Get a TTB Federal Basic Importer’s Permit
Before you can import alcohol for commercial sale, you must obtain a Federal Basic Permit as an importer from the TTB. This is a prerequisite — you cannot lawfully import beverage alcohol for resale without it. Many businesses also need a wholesaler’s basic permit if they’ll sell to retailers, and state-level licenses apply separately on top of the federal permit.
2. Obtain a COLA for Each Label
Most imported beverage alcohol must have an approved Certificate of Label Approval (COLA) before CBP will release it. You apply to TTB’s Alcohol Labeling and Formulation Division for each unique product/label, and the label must meet TTB’s content requirements (mandatory information, health warning, and so on). No COLA, no release — so build the approval time into your schedule.
3. File FDA Prior Notice
Because the FDA treats alcoholic beverages as food, every shipment requires an electronic Prior Notice filed with the FDA before the goods arrive at the first U.S. port. Missing or late prior notice is a common cause of holds and refusals at the border.
4. Pay Federal Excise Tax and Duties
Imported distilled spirits, wine, and beer are subject to federal excise tax under the Internal Revenue Code, which CBP collects at entry, along with any customs duties based on the product’s classification and origin. Excise tax on alcohol is significant and varies by product type and alcohol content, so factor it into your landed cost from the start.
The Sequence at a Glance
| Step | Agency | What it is |
|---|---|---|
| Basic Importer’s Permit | TTB | Permission to import alcohol for commercial sale |
| COLA | TTB | Label approval, required before customs release |
| Prior Notice | FDA | Advance notice of each food (alcohol) shipment |
| Excise tax + duties | CBP collects | Federal excise tax and import duties at entry |
Beyond these federal steps, state alcohol laws (licensing, the three-tier distribution system, and registrations) apply wherever you sell — alcohol is regulated at both levels, so federal compliance is necessary but not sufficient.
Frequently Asked Questions
What permits do I need to import wine or spirits?
A TTB Federal Basic Importer’s Permit is required to import beverage alcohol for commercial sale, and many importers also need a wholesaler’s basic permit. State licenses apply separately. You’ll also need a COLA for each label and must file FDA prior notice for each shipment.
What is a COLA?
A Certificate of Label Approval issued by the TTB. Most imported beverage alcohol must have an approved COLA — confirming the label meets federal requirements — before U.S. Customs will release the shipment. You apply to TTB for each unique product label.
Why does the FDA regulate imported alcohol?
Because alcoholic beverages are “food” under FDA rules, so FDA requirements apply, including filing an electronic Prior Notice before each shipment arrives. This is in addition to the TTB permit and label requirements.
What taxes apply to imported alcohol?
Federal excise tax under the Internal Revenue Code, collected by CBP at entry, plus customs duties based on classification and origin. Alcohol excise tax is substantial and varies by beverage type and alcohol content, so include it in your landed-cost calculations.
Importing alcohol is a multi-agency compliance project where a missing permit or label approval stops the shipment cold. Reidel Law Firm helps alcohol importers navigate TTB, FDA, and customs requirements on flat-fee terms. Get an import compliance memo.
