Public TTB & 50-State Beverage DTC Compliance Guide
Essential regulatory compliance framework for US wineries 🍷, craft distilleries 🥃, and craft breweries 🍺 shipping direct-to-consumer nationwide.
"Compliance doesn't have to be overwhelming! I've summarized the key rules for wineries, distilleries, and craft breweries into friendly, bite-sized steps so your team can ship with total peace of mind."
1. Federal TTB 27 CFR Labeling & COLA Approvals
Under 27 CFR Part 4 (Wine), Part 5 (Distilled Spirits), and Part 7 (Malt Beverages), commercial SKUs intended for interstate commerce must secure a Certificate of Label Approval (COLA), Certificate of Exemption, or formula authorization from the Alcohol and Tobacco Tax and Trade Bureau (TTB). Mandatory records must be retained for at least 36 months from the record date or date of required entry.
2. Multi-Commodity Direct Shipping Permits & Volume Caps
Over 45 US states permit direct-to-consumer (DTC) wine shipping, while spirits DTC and craft beer DTC rules vary widely across state ABC jurisdictions. Annual per-consumer volume caps and state permit requirements vary by commodity (e.g., 36 cases/yr for wineries in NY, 9 gallons per calendar month in TX [36 gallons/12-mo limit], and specialized direct shipper permits in KY/AK).
3. 10DLC Campaign Vetting & SHAFT Age-Gate Compliance
U.S. A2P 10DLC text messaging for alcohol brands requires brand registration under the carrier SHAFT (Sex, Hate, Alcohol, Firearms, Tobacco) framework. All promotional messaging requires documented opt-in consent, clear opt-out handlers, and age-gating (21+) as applicable to alcohol messaging requirements.
4. Carrier Compliance & Package Labeling (ASR 21+)
Alcohol shipments require dedicated carrier Alcohol Shipper Agreements (e.g. FedEx U.S. consumer shipments are limited to wine, while beer and spirits require licensee-to-licensee shipping). Deliveries require Adult Signature Required (ASR - 21+) delivery service alongside required outer package alcohol labels. Shipping beverage alcohol via the United States Postal Service (USPS) is strictly prohibited by federal statute.
5. HeatGuard™ Route Thermal Risk & Cold-Chain Protocols
Extreme ambient temperatures cause cooking (cork push/leakage) at >82°F for delicate varietals like Pinot Noir and >85°F for Cabernet. Wineries must evaluate 14-day route weather forecasts, issue seller-branded hold notices, or dispatch via climate-controlled reefer trucks.
6. Ecosystem Integration & Vinoshipper Partner Boundaries
CaskStack functions as an automated marketing & customer engagement utility sitting on top of compliance partners like Vinoshipper, Commerce7, and ShipCompliant. Vinoshipper manages state sales tax collection, excise tax remittance, monthly state return filings, and DTC permits, while CaskStack powers pre-checkout dunning, age gates, print collateral, and route weather holds.
7. TTB 27 CFR § 16.21 Warning Statements & Advertising Rules
Alcoholic beverage container labels require the mandatory Surgeon General health warning statement under 27 CFR Part 16. Hang tags, bottle cones, and promotional collateral are classified as advertising material subject to applicable TTB advertising rules.
8. CaskSafe™ Local Option Dry County & Reciprocity Matrix
The CaskSafe™ engine evaluates recipient addresses against our 50-state compliance matrix, modeling local-option eligibility by state, permit type, and commodity. It detects local option dry county precincts (KY, MS dry rules; TX permits DTC wine under TABC § 54.01), state annual volume cap limits, and reciprocity bans (e.g. Utah non-direct shipping) before billing runs.