Compliance with TTB regulations generally requires alcohol producers to maintain detailed records. While TTB recordkeeping requirements vary by permit type and specific operations, for example, recordkeeping regulations for beer production are found under 27 CFR Part 25, recordkeeping regulations for wine are found under 27 CFR Part 24, and recordkeeping regulations for Distilled Spirits are found under 27 CFR Part 19. Proper recordkeeping is essential for TTB regulatory compliance, federal excise tax reporting, and audit preparedness. Maintaining accurate and accessible records is a fundamental requirement for TTB regulated industry members. Industry members should refer to regulations that specifically cover their operations for a thorough understanding. Generally speaking, these requirements have been broken down below, while this is not an exhaustive list, it covers many general records for TTB compliance.
General Records for TTB Compliance
1. Production Records:
In order to have precise records of your production it is often best to keep record of ingredient data, methods of manufacturing, and identification documents. You should keep detailed records of all ingredients used in the production process, including types, quantities, and sources, as well as documentation of the steps involved in production, such as fermentation, distillation, or blending. For your production, you may need identification of each batch or lot produced, along with corresponding production dates.
2. Inventory Records:
For most accurate inventory records you should keep documentation of raw materials, finished products, and aging and storage. You must track inventory of any raw materials, which can include, grains, fruits, sugars, hops, and other ingredients as well as inventory levels of finished products, which can include beer, wine, spirits, or other alcoholic beverages. Lastly, you must keep documentation of aging and storage conditions for products maturing in barrels or tanks.
3. Taxpaid Removals and Federal Excise Tax Records:
It is extremely important to keep records of excise tax calculations, excise tax payments, and excise tax returns. For most precise recordkeeping, excise tax calculations can include the calculations for each batch or lot produced. Excise tax returns and payments should be kept and include the dates they are paid/filed and what was paid/filed.
4. Labeling and Packaging Records:
Manufacturers should keep records of their Certificate of Label Approval ("COLA") applications, including the COLA number and label that was approved by said COLA. Additionally, if a formula is required for the product, it is important to keep records of the approved formula and any specification sheets, FID sheets, or any other formula documents. For the most precise recordkeeping, inventory records of packaging materials, such as bottles, caps, labels, and packaging boxes can be kept.
5. Quality Control and Testing Records:
In order to ensure safety and quality, it is best to keep documentation of quality control measures implemented during production, including testing procedures and results and records of laboratory analysis conducted on raw materials, intermediate products, and finished goods to ensure quality and safety standards are met.
6. Record Retention:
TTB regulations require alcohol producers to maintain records for specified periods, which is typically about 3 years, but may vary based on the regulation. Records must be readily accessible for inspection by TTB officials upon request.
7. Electronic Recordkeeping:
The TTB permits electronic recordkeeping, provided that records are maintained in a secure and accessible format. Electronic records must be maintained in a manner that ensures their integrity, authenticity, and confidentiality.
While this list is not exhaustive of every type of records that could be required for permit holding entities, it covers many basic requirements for different permitholders. Please understand TTB recordkeeping is not a one-size fits all situation, so if you have any questions regarding your specific reporting and recordkeeping requirements, contact an attorney with experience with TTB compliance, or visit TTBs website to learn more (Information For... | TTB: Alcohol and Tobacco Tax and Trade Bureau).