Solera Winery Compliance Guide

Pennsylvania Winery Compliance & Reporting Guide: 2026

By Kevin Nesgoda, winemaker and founder of Solera ·

Direct answer: A Pennsylvania winery typically manages three compliance tracks: PLCB licensing and limited-winery records, Pennsylvania tax and reporting through PA Commodities, PLCB+, and myPATH when applicable, and federal TTB obligations for bonded wine premises. Direct wine shippers add quarterly PLCB+ reporting and a $2.50-per-gallon wine excise return. Exact filings depend on license type, production model, and sales channels.

Pennsylvania winery compliance calendar at a glance

ObligationWho filesWhenWhereWhat to know
Limited-winery sales/production reportPLCB limited wineriesMonthly workflowPA CommoditiesPLCB's current instructions tell licensees to report gallons sold monthly. The guide does not publish a universal day-of-month deadline, so do not invent one.
Wine Marketing producer chargeWine producers subject to the programPayable monthly or after year end in the online workflow; annual producer charge is due by February 1 under 7 Pa. CodePA CommoditiesCurrent operational rate is $0.20 per gallon of wine sold. In-state winery-to-winery transfers in bond are excluded by the regulation.
Calendar-year licensed-operations reportPLCB limited wineriesAt license renewal or validationPLCB process40 Pa. Code § 5.409 requires the preceding calendar year's report and a retained copy for at least two years.
DWS Sales by Product reportDirect Wine Shipper licenseesQ1 Apr. 30; Q2 Jul. 31; Q3 Oct. 31; Q4 Jan. 31PLCB+File every quarter while licensed, including a no-sales report when applicable.
DWS wine excise returnDirect Wine Shipper licenseesQuarterly, due the 20th day after each calendar quartermyPATH$2.50 per gallon. A return is required even with no taxable activity.
PA sales taxDWS and other sellers as applicablePer the filing frequency assigned to the tax accountmyPATHState sales tax is 6%, plus 1% local tax in Allegheny County or 2% local tax in Philadelphia where applicable.
TTB Form 5120.17Bonded wineries and bonded wine cellarsMonthly unless eligible for quarterly or annual filingPay.gov or TTB's permitted paper methodGenerally due on the 15th day after the reporting period. Eligibility depends on federal criteria, not Pennsylvania license type.
Federal excise tax return, TTB Form 5000.24Taxpayers with wine excise tax liabilityAnnual, quarterly, or semimonthly based on eligibilityPay.govUse TTB's current due-date calendar because federal holiday rules can shift specific dates.
FDA food-facility renewalFacilities required to register with FDAOct. 1 through Dec. 31 of each even-numbered yearFDA Industry Systems2026 is a renewal year. Registration exemptions are fact-specific.

Who this Pennsylvania winery guide covers

This guide is centered on a Pennsylvania limited winery, the license class commonly used by Pennsylvania producers with direct retail privileges, and it separately covers Direct Wine Shipper (DWS) obligations for eligible in-state or out-of-state wine producers shipping to Pennsylvania residents. Federal sections apply when the premises is a TTB-qualified bonded winery or bonded wine cellar.

Under 40 Pa. Code § 5.401, a Pennsylvania limited winery produces at least 200 gallons but not more than 200,000 gallons of winery products for each full calendar year its license is active. The governing Liquor Code § 505.2 also caps annual production at 200,000 gallons.

License class matters. A full Pennsylvania winery license, a limited winery license, a DWS license, and a federal bonded-winery authorization are not interchangeable. Before using any deadline in this guide, match it to the licenses and sales channels your business actually uses.

Licensing and setup before operations

1. Qualify the federal wine premises when required

A business operating a bonded winery or bonded wine cellar must receive TTB approval before beginning the regulated wine operations covered by its application. TTB currently processes winery qualification through Permits Online and explains the winery application paths in its Federal Application Process.

2. Obtain the correct PLCB license

PLCB licensing depends on the planned activity. For a Pennsylvania limited winery, current PLCB materials and 40 Pa. Code Subchapter K govern limited-winery operations. Keep the approved premises, storage, additional locations, and privileges aligned with the license record.

3. Register for state reporting and tax accounts that apply

The limited-winery reporting workflow uses PA Commodities and a six-character winery code. DWS applicants use PLCB+. DWS tax accounts, including Wine Excise, are registered through Pennsylvania Online Business Tax Registration and administered in myPATH.

Pennsylvania limited-winery reporting and records

Monthly PA Commodities reporting

PLCB's current Limited Winery Instructions for Filing Monthly Reports says a PLCB limited winery must file monthly reports detailing wine production and that the online process satisfies reporting obligations to both the PLCB and Pennsylvania Department of Agriculture in a single workflow. The procedure is:

  1. Open PA Commodities and register using the winery's six-character Winery Code.
  2. Select the winery, calendar year, and reporting month.
  3. Enter the gallons sold for the month. The system calculates the producer charge.
  4. Confirm the submission and retain the confirmation with the winery's compliance records.
  5. Use the system's payment workflow for monthly payment or the available single installment after year end.

The current PLCB procedural guide does not state a single day-of-month deadline for each monthly entry. This guide therefore does not supply one. Build a monthly close that submits promptly after reconciliation, and follow any deadline shown in the live portal or PLCB notice.

The current Wine Marketing producer charge is $0.20 per gallon

The current PA Commodities portal says the assessment rate changed from $0.15 to $0.20 per gallon effective January 1, 2015, and PLCB's current limited-winery reporting guide also uses $0.20 per gallon of wine sold. 7 Pa. Code § 104.73 still prints $0.15 but expressly permits a later change through amendment or referendum. The same regulation excludes sales or transfers in bond from one Pennsylvania winery to another from the charge.

7 Pa. Code § 104.75 requires the annual producer charge to be mailed or delivered by February 1 following the previous marketing season. The online PLCB instructions allow payment monthly or in a single installment after year end. Reconcile all twelve months before the annual payment deadline.

Annual report at renewal or validation

40 Pa. Code § 5.409(f) separately requires a report covering the preceding calendar year's licensed operations when the license is renewed or validated. A copy must be kept for at least two years, and failure to file can prevent renewal or validation. Because PLCB's newer procedural instructions describe a monthly online workflow that fulfills both PLCB and Agriculture reporting, preserve monthly confirmations and complete any additional report or certification presented in the renewal or validation process.

Daily records and delivery receipts

Limited wineries must keep permanent daily records at the licensed premises, including complete source information for agricultural commodities used in production. Electronic records are permitted when they are reconcilable and verifiable under the requirements of 40 Pa. Code § 5.409.

For delivered winery products, prepare two receipt copies. One must be signed by a person at least 21 years old who receives the delivery, and the limited winery must retain the signed copy for two years. A sale to a private individual exceeding 16 liters in a single transaction also triggers the specific sales-receipt fields listed in § 5.409.

Production source and operating boundaries

Liquor Code § 505.2 generally ties limited-winery production to Pennsylvania-grown agricultural commodities, subject to statutory exceptions. One current exception allows an approved permit for up to 25% permitted fruit in a calendar year's production; “permitted fruit” is fruit, or juice from fruit, grown within 350 miles of the winery. Do not treat that exception as a blanket right to source finished wine from outside Pennsylvania.

Direct Wine Shipper compliance for Pennsylvania

A winery shipping wine directly to Pennsylvania residents needs the DWS privilege unless a different statutory privilege specifically authorizes the transaction. PLCB's current How to Become a Direct Wine Shipper page says eligible wine producers apply through PLCB+, submit proof of a wine-producer license, and pay a $250 initial filing fee. The annual renewal fee is also $250.

A DWS license permits shipment of up to 36 cases per Pennsylvania resident per calendar year for personal use, with no more than 9 liters per case. PLCB guidance also limits DWS shipments to wine produced by the licensee.

Quarterly PLCB+ Sales by Product report

PLCB's Amended Advisory Notice No. 23 implements DWS reporting as a quarterly Sales by Product report in PLCB+. File for every quarter in which you hold the license, including a no-sales quarter.

QuarterPeriodPLCB+ report dueDWS wine excise return due
Q1Jan. 1 to Mar. 31Apr. 30Apr. 20
Q2Apr. 1 to Jun. 30Jul. 31Jul. 20
Q3Jul. 1 to Sep. 30Oct. 31Oct. 20
Q4Oct. 1 to Dec. 31Jan. 31Jan. 20

These are different filings with different due dates. The PLCB+ product report is not the myPATH Wine Excise return.

PLCB's line-by-line instructions require each product to be reported separately and identify fields including year, quarter, product name, bottle size in milliliters, units sold as bottles, total gross sales, UPC when available, varietal, and vintage. Total gross sales for this report exclude wine excise tax and shipping charges. For a no-sales quarter, use PLCB's item-by-item no-sales procedure rather than a zero-value Excel upload.

DWS Wine Excise tax and sales tax

The Pennsylvania Department of Revenue's current Wine Excise Tax page sets the DWS wine excise tax at $2.50 per gallon. File the return and payment through myPATH quarterly by the 20th day after each calendar quarter. A Wine Excise return is required even when there were no taxable transactions.

DWS transactions are also subject to applicable Pennsylvania state and local sales tax. Pennsylvania's current licensee tax guidance states a 6% state sales tax, with an additional 1% in Allegheny County and 2% in Philadelphia. The Department of Revenue states that the 18% liquor tax does not apply to DWS shipments. Sales-tax filing frequency is account-specific, so use the frequency assigned to the winery in myPATH rather than copying the DWS excise schedule.

Age checks, package notice, and delivery

PLCB requires proof of age before DWS shipment and age verification at delivery. Packages must be conspicuously marked: “CONTAINS ALCOHOL: SIGNATURE OF PERSON 21 YEARS OF AGE OR OLDER REQUIRED FOR DELIVERY.” Current PLCB guidance generally requires delivery by a transporter-for-hire licensed to transport wine.

There is a specific in-state limited-winery exception worth separating from the general rule: 40 Pa. Code § 5.407 allows a Pennsylvania limited winery to deliver its own products in its own vehicle, but delivery of wine or wine coolers to an unlicensed Pennsylvania individual still requires a DWS license. The DWS requirement applies whether the limited winery self-delivers or uses a transporter.

Federal TTB reporting still applies

Pennsylvania reporting does not replace federal winery compliance. Bonded wineries and bonded wine cellars must file TTB Form 5120.17, Report of Wine Premises Operations, monthly unless they qualify for quarterly or annual filing under 27 CFR § 24.300(g).

  • Annual: TTB's current guide describes eligibility as no more than 20,000 gallons of wine on hand at any time and eligibility to file the federal excise tax return annually. The report is due January 15 following the calendar year.
  • Quarterly: TTB's current guide describes eligibility as no more than 60,000 gallons on hand at any time and eligibility to file the federal excise tax return quarterly. Reports are due April 15, July 15, October 15, and January 15.
  • Monthly: Wineries outside the annual or quarterly eligibility criteria file monthly, generally by the 15th day after the reporting month.

Eligibility can change with activity and tax status, so apply the full rule in 27 CFR § 24.300(g), including its change-of-frequency requirements. Federal excise tax returns follow a separate annual, quarterly, or semimonthly schedule. Check TTB's current due-date calendar for the exact tax return date.

TTB records and source records prescribed by 27 CFR § 24.300 generally must be retained for at least three years from the record date or last entry, whichever is later, and TTB may require an additional retention period of up to three years. For a field-by-field workflow, see Solera's TTB Form 5120.17 instructions.

FDA food-facility registration: check whether your winery is covered

FDA requires domestic and foreign facilities that manufacture, process, pack, or hold food for U.S. consumption to register unless an exemption applies under federal law. FDA's Registration and Listing guidance points to the exemptions in 21 CFR § 1.226. Do not assume every winery has the same registration status.

If the winery facility is required to register, FDA requires biennial renewal between October 1 and December 31 of each even-numbered year. That makes 2026 a renewal year. Use FDA's current Biennial Registration Renewal instructions.

Records a Pennsylvania winery should reconcile

The safest compliance workflow starts from one reconciled operational ledger, then maps the required values into each regulator's form. At minimum, preserve the records that support these filings:

Record areaMinimum compliance useAuthority
Agricultural commodity sourceSource details supporting limited-winery production40 Pa. Code § 5.409
Daily production and inventoryReconcile gallons produced, on hand, removed, transferred, and sold40 Pa. Code § 5.409; 27 CFR Part 24
Monthly gallons soldPA Commodities monthly report and producer-charge calculationPLCB limited-winery instructions
Large private salesRequired receipt information when a private-individual transaction exceeds 16 liters40 Pa. Code § 5.409
Limited-winery deliveriesTwo receipt copies and signed 21+ delivery receipt retained two years40 Pa. Code § 5.409
DWS order and customerResident, address, age-verification evidence, shipment date, product, volumePLCB DWS guidance
DWS product salesProduct, bottle size mL, bottles sold, gross sales excluding excise and shipping, UPC if available, varietal, vintagePLCB+ reporting instructions
DWS gallons and tax$2.50/gallon excise calculation and applicable sales taxPA Department of Revenue
Federal source recordsSupport Form 5120.17 and federal excise tax returns27 CFR § 24.300

Practical monthly and quarterly checklist

Every month

  • Close production, inventory movements, removals, and sales against source records.
  • For a PLCB limited winery, complete the PA Commodities monthly report and retain confirmation.
  • Calculate and reconcile the current $0.20-per-gallon Wine Marketing producer charge.
  • File TTB Form 5120.17 if the federal premises is on a monthly schedule.
  • Archive delivery receipts and age-verification evidence tied to the transaction.

Every quarter

  • If licensed as a DWS, reconcile bottles, bottle sizes, gross product sales, and gallons shipped.
  • File the PLCB+ Sales by Product report by the quarter-end reporting deadline, including no-sales reporting.
  • File the myPATH Wine Excise return by the 20th day after quarter end, including a zero return when applicable.
  • File TTB Form 5120.17 and federal excise tax returns if the winery is on the applicable quarterly schedule.

At year end and renewal

  • Reconcile twelve months of PA Commodities activity and the annual producer-charge amount before the February 1 deadline.
  • Complete the preceding-calendar-year PLCB report or certification required at renewal or validation, and retain a copy for at least two years.
  • Check DWS resident-level shipment totals against the 36-case annual limit.
  • If FDA registration is required, renew between October 1 and December 31 in an even-numbered year.

Common Pennsylvania compliance mistakes

  1. Using the old $0.15 Wine Marketing rate. The live portal and current PLCB instructions use $0.20 per gallon.
  2. Treating PLCB+ and myPATH as one quarterly filing. DWS product reports are due on the 30th or 31st after quarter end; Wine Excise returns are due on the 20th.
  3. Skipping a zero-activity filing. PLCB DWS guidance requires quarterly reporting while licensed, and Revenue requires a Wine Excise return even with no taxable transactions.
  4. Reporting cases where PLCB asks for bottles. The DWS Sales by Product workflow uses units sold as bottles and bottle size in milliliters.
  5. Including shipping or wine excise tax in PLCB gross sales. PLCB's product-report instructions exclude both from the gross-sales value.
  6. Assuming self-delivery removes the DWS requirement. A Pennsylvania limited winery may self-deliver its own products under § 5.407, but delivery of wine to an unlicensed Pennsylvania individual still requires DWS authority.
  7. Letting state and federal inventories drift apart. Pennsylvania reports and TTB reports use different forms, but both should reconcile to the same underlying cellar and sales activity.

Pennsylvania winery compliance FAQs

How often must a Pennsylvania limited winery report wine sales?

PLCB's current limited-winery instructions direct licensees to use PA Commodities for monthly reports of gallons sold. The regulation separately requires a report covering the preceding calendar year's licensed operations at renewal or validation. Keep confirmation of monthly submissions and complete any renewal or validation reporting the PLCB requires.

What is Pennsylvania's current Wine Marketing producer charge?

The current PA Commodities portal and PLCB reporting instructions state a producer charge of $0.20 per gallon of wine sold. The codified regulation still prints $0.15 but expressly allows the charge to be changed by later amendment or referendum. The portal states the rate changed to $0.20 effective January 1, 2015.

When are Pennsylvania Direct Wine Shipper reports due?

PLCB Sales by Product reports are due quarterly: April 30, July 31, October 31, and January 31 for the preceding quarter. A DWS licensee must report even when it had no Pennsylvania shipments during the quarter.

What tax applies to Direct Wine Shipper sales in Pennsylvania?

Pennsylvania imposes a $2.50 per gallon wine excise tax on DWS sales, plus applicable state and local sales tax. The Pennsylvania Department of Revenue states that the 18% liquor tax does not apply to DWS shipments. Wine Excise returns are filed quarterly through myPATH and are due on the 20th day after each calendar quarter, including zero-activity returns.

How much wine can a Direct Wine Shipper send to a Pennsylvania resident?

A DWS licensee may ship up to 36 cases per calendar year to a Pennsylvania resident for personal use, and each case may contain no more than 9 liters.

How long must a Pennsylvania limited winery retain delivery receipts?

For delivered winery products, 40 Pa. Code § 5.409 requires a receipt signed by a person at least 21 years old and requires the limited winery to retain the signed copy for two years.

How often is TTB Form 5120.17 filed?

Bonded wineries and bonded wine cellars file Form 5120.17 monthly unless they qualify for quarterly or annual filing under 27 CFR § 24.300(g). TTB's current guide describes annual eligibility for premises with no more than 20,000 gallons on hand at any time and annual federal excise tax filing, and quarterly eligibility for no more than 60,000 gallons on hand at any time and quarterly tax filing.

Does every winery have to renew an FDA food facility registration in 2026?

No. FDA registration applies to facilities that must register under federal food-facility rules, subject to exemptions. A winery that is required to register must renew between October 1 and December 31 of each even-numbered year, including 2026. Confirm whether an exemption applies to your facility before relying on it.

Official sources used to verify this guide

Material legal, filing, deadline, rate, and recordkeeping claims were checked against current primary government sources. Pages and instructions were rechecked August 5, 2026.

  1. 40 Pa. Code, Chapter 5, Subchapter K: Limited WineriesPennsylvania Code and Bulletin. Controlling rules for limited-winery definitions, delivery, records, and reporting.
  2. Liquor Code § 505.2: Limited WineriesPennsylvania General Assembly. Statutory privileges, production cap, agricultural-commodity rules, and permitted-fruit provision.
  3. Limited WineriesPennsylvania Liquor Control Board. Current licensing overview and official reporting resources.
  4. Limited Winery Instructions for Filing Monthly ReportsPennsylvania Liquor Control Board. PA Commodities workflow and current $0.20 producer charge.
  5. Pennsylvania Wine Marketing and Research Program ApplicationPennsylvania Department of Agriculture. Live PA Commodities portal; states the $0.20 rate effective January 1, 2015.
  6. 7 Pa. Code, Chapter 104, Subchapter FPennsylvania Code and Bulletin. Producer-charge legal basis, in-bond exclusion, annual statement, and February 1 deadline. The codified rate text is historical; see the current portal rate above.
  7. How to Become a Direct Wine ShipperPennsylvania Liquor Control Board. Current DWS eligibility, limits, fees, tax, age, and delivery requirements.
  8. Amended Advisory Notice No. 23: Direct Wine Shipper LicensePennsylvania Liquor Control Board. Quarterly reporting schedule and age-verification implementation.
  9. DWS Sales by Product Line-by-Line Reporting InstructionsPennsylvania Liquor Control Board. Required product fields, bottle-unit reporting, and no-sales procedure.
  10. Wine Excise TaxPennsylvania Department of Revenue. $2.50-per-gallon rate, quarterly filing, zero returns, and myPATH.
  11. Tax Information for LicenseesPennsylvania Department of Revenue. State and local sales tax rates applicable to licensees.
  12. Report of Wine Premises OperationsAlcohol and Tobacco Tax and Trade Bureau. Current Form 5120.17 frequency and filing guidance; page updated October 15, 2025.
  13. 27 CFR Part 24, Subpart O: Records and ReportsElectronic Code of Federal Regulations. Federal wine records, retention, and reporting-frequency rules.
  14. Due Dates for Tax ReturnsAlcohol and Tobacco Tax and Trade Bureau. Current federal excise tax filing calendar.
  15. Registration and Listing and Biennial Registration RenewalU.S. Food and Drug Administration. Registration scope, exemptions, and even-year renewal window.

Verification notes and changelog

Version 1.0, August 5, 2026: First English edition. Verified Pennsylvania limited-winery rules, PA Commodities reporting, current Wine Marketing producer-charge rate, DWS licensing and quarterly reports, Wine Excise tax, federal TTB reporting, and 2026 FDA renewal timing. Resolved the legacy $0.15 codified producer-charge text against the current $0.20 operational rate stated by PA Commodities and PLCB.

Next scheduled review: November 5, 2026, or sooner if PLCB, Pennsylvania Revenue, TTB, or FDA changes a form, rate, portal, deadline, or governing rule.

Compliance disclaimer: This guide is general educational information, not legal, tax, or accounting advice. Winery obligations depend on license type, location, production model, transactions, and facts. Rules, forms, portal behavior, fees, and deadlines can change. Confirm current requirements with the Pennsylvania Liquor Control Board, Pennsylvania Department of Agriculture, Pennsylvania Department of Revenue, TTB, FDA, and qualified counsel or tax professionals before filing or relying on this guide.

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Disclaimer: This guide is for informational purposes only and is not legal, tax, or compliance advice. Verify all requirements with the relevant regulatory agency.