What Records a Bonded Winery Has to Keep

Which records does TTB actually require?

Records covering every operation that changes the identity, volume, or location of wine on bonded premises. The requirements live in subpart O of 27 CFR part 24, and they are organized by operation rather than by document.

Read that list as a description of the cellar rather than a filing checklist and it becomes far less intimidating. Every item corresponds to a thing that physically happened, witnessed by someone who was standing there. The regulation is not asking for anything a competent cellar does not already know; it is asking for that knowledge to exist somewhere other than in a cellar hand's memory.

How long do you have to keep them?

Not less than three years from the record date or the date of the last entry required to be made in the record, whichever is later. That is the baseline in 27 CFR 24.300.

There is an extension provision. A TTB officer may require records to be kept for an additional period not exceeding three more years where retention is determined to be necessary, which makes six years the realistic planning horizon rather than three. Wineries that dispose of records at exactly three years are technically compliant right up until they are asked for year four.

The "whichever is later" clause matters more than it reads. A running account of a bulk lot that stays open for four years in barrel does not start its retention clock at the first entry; it starts at the last one. For a winery producing library and reserve wines, some records will be live for the better part of a decade before their retention period even begins.

What counts as an acceptable record?

Anything that contains the required information and can be verified. TTB does not prescribe a form for most winery records, which surprises people who expect a federal filing regime to hand them a template.

This is genuinely permissive. Records kept in the ordinary course of business are acceptable, which means a commercial invoice can serve as a receiving record, a lab worksheet can serve as an analysis record, and a work order can document an addition, as long as each carries the details the regulation calls for. Electronic records are acceptable on the same terms: contain the required information, retain it for the required period, and produce it for inspection on request.

The flexibility is also the trap. Because no form is prescribed, nothing tells you when a record is inadequate until an auditor does. A cellar log entry reading "SO2 added, T4" satisfies nobody: it lacks the quantity, the date is only implied by page order, and "T4" identifies a tank rather than a lot. The same event recorded as "2026-09-14, Lot 26-CS-03 in T4, added 4.2 kg potassium metabisulfite, initials KN" is complete. The difference costs three seconds at the time and is unrecoverable two years later.

Why source records matter more than summaries

Because a summary nobody can trace back is not evidence of anything. Proprietors are required to retain source records and supplemental records that support entries in other records, specifically so that operations can be verified rather than merely asserted.

A source record is the original document the entry came from: the weigh tag from the scale, the lab sheet with the analysis, the transfer log from the day of the rack, the bill of lading from the shipment. The summary record, the running account of bulk wine by tax class, is derived from those. An auditor examining a suspicious volume on the summary will ask for what it was derived from, and "we compiled it from memory at quarter end" is the answer that turns a routine review into something longer.

The practical test is whether any single number on any filed report can be traced to a dated, specific, contemporaneous record of the event that produced it. If it can, the winery is in good shape regardless of how the records look. If it cannot, the filings are unsupported no matter how neatly they were prepared.

What does TTB look at first?

Documentation supporting the Report of Wine Premises Operations, which is the most commonly cited deficiency in TTB reviews of wineries. The report is filed; the records behind it are non-existent or inadequate.

Compliance issues found in winery reviews cluster into four areas: records, inventory, reporting and tax payment, and permits, registration, and bonds. Records sit first in that list because they underpin the other three. An inventory discrepancy is only resolvable against records. A reporting error is only correctable if the underlying events were captured. A tax underpayment is only quantifiable from documented removals.

The specific things that draw attention are unglamorous. Gaps in a running account where wine appears or disappears without a documented movement. Additions recorded without quantities. Losses booked without an explanation of cause. Transfers between vessels with no volume recorded, which makes the topping and racking losses impossible to verify. Bottling runs whose case counts do not reconcile to the bulk volume drawn down. None of these are exotic failures; they are the predictable result of recording events at the end of the week instead of at the moment they happen.

How records connect to the reports you file

Every number on the Report of Wine Premises Operations and every gallon on the excise tax return is a summary of records you were already required to keep. The reports are outputs, not separate obligations.

That relationship is why the reports are hard for wineries that treat compliance as a periodic activity. If production, additions, transfers, and removals are captured as they occur, the report is a query over records that already exist. If they are not, the report is a reconstruction exercise conducted from invoices, memory, and a whiteboard that has been erased twice since.

The reconstruction usually produces a number that is close enough to file. It does not produce records, and the filing then rests on evidence that was never created. This is precisely the gap that shows up as inadequate documentation in a review: the report was right, and nothing behind it can prove it.

An annual physical inventory sits at the same junction. A proprietor filing monthly or quarterly reports must record a physical inventory of all wine and spirits in storage at the close of business for each tax year, and retain it with the operations report for the period in which it was taken. Wineries that keep continuous vessel level records find the annual inventory confirms what they already knew. Wineries that do not find out in January how far the year drifted.

Frequently asked questions

The record is the compliance, the report is just the receipt

It is possible to file every report on time for years and still fail a review, because the reports are not the obligation. The obligation is a contemporaneous, traceable account of what happened to wine on your premises, retained for three years and possibly six, complete enough that a stranger can follow a lot from fruit receipt to removal without asking anyone what they remember. A winery that has that can file anything asked of it in an afternoon. A winery that does not has been running on a reconstruction it will eventually be asked to prove.

Solera captures those events where they happen: additions written to an append-only log in the TTB Compliance module, vessel transfers and volumes in the Cellar and Fermentation module, lab results against the lot in Vintage and Lab, and bottling runs drawn down from the bulk volume they came from. The record accumulates because the winery is being run, not because someone remembered to write it down.

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