FDA & TTB Compliance: A Checklist for Winery Operations
It’s always a good time to gut-check your wine production record-keeping, but it’s especially valuable to do so each year before harvest begins.
Every producer of wine or hard cider is required to keep thorough compliance records for the TTB and FDA. This documentation requires immaculate tracking of liquid movements across each tax class and bond, all ingredients added to your products, analysis history and compositional history tracking back to the source fruit, juice or wine.
It’s near impossible to manage this with spreadsheets! If you are, you’re likely spending far too much time and effort making sense of your production notes, and, let’s be honest, fudging a few numbers here and there. So, how can you make sure you’re tracking everything correctly and efficiently?
Button up your record-keeping
Legally speaking, what are some of the requirements that need to be tracked and documented?
All liquid movements and evaporative losses
Believe it or not, every gallon of wine needs to be accounted for as it moves between vessels at your winery, and even as it evaporates over time! These needs to be documented with a reliable audit trail.
Every product added to grapes, juice and wine
Make sure all additive quantities are tracked, both into the wine and back to the manufacturer batch and purchase order. The FDA requires this audit trail.
Wine transferred between tax classes
For example, if you blend a wine that’s 15.5% ABV into a wine that’s 16.1% ABV, this transferred volume needs to be documented currently on the 5120.17 report as being removed from <16% tax class and transferred to the 16-21% tax class.
Wine transferred between bonds
Not only to an offsite bond, but if you’re maintaining multiple APs at your winery, between APs as well! These are bond-to-bond transfers, and need to be reported to the TTB as such.
Physical inventory record
You are required to do a physical inventory count at least once a year. The end of period inventory needs to match the 5120.17 report that you submitted to the TTB.
The full history for every wine produced
If the TTB comes knocking on your door they’ll require for a full audit trail for at least one of your final products including additives, record of volume changes over time, analysis history, associated work orders, and evidence of label compliance for vintage, varietal and appellation at a minimum.
Sound overwhelming? It should, if you’re tracking all this by hand… This is where software tags in to help.
Utilize winery management software for TTB compliance
By managing your winemaking with InnoVint, your winemaking volume, tax class and bonded activities are automatically captured, the compliance implications are properly categorized, and TTB report generation is done for you by the software itself.
When it’s time to submit the TTB 5120.17 form, it’s just a few clicks in InnoVint and the form is exported to a PDF pre-populated with your winery’s activities by tax class.
With better software in place, InnoVint:
*Produces your information on the actual Report of Wine Premises Operations form and enables further editing if needed
*Supports multiple bonds at a single location
*Supports multiple locations under the same organization
*Supports monthly, quarterly, or annual reporting periods
*Pop-up notifications alert users of potential compliance issues, such as blending across
tax classes or bonds, while using the software
*Tax class decorations can be edited and backdated
*Grant access to your compliance team 3rd party consultants to run the report themselves!
If you do get audited, InnoVint provides the traceability trail for every wine in a single report that satisfies TTB and FDA requirements, with the digital work order history linked as well.
Put InnoVint in place today prior to Harvest 2020! Contact us to make sure you’re set up for success this season and beyond.