International Affairs Division (IAD)

Exporting Wine from the U.S.

Wholesalers Withdrawing Wine from Bonded Wine Cellar Without Payment of Tax

The following addresses the most pertinent regulatory requirements pertaining to wholesalers withdrawing wine from bonded wine premises without payment of tax for:

  • Exportation;
  • Use as supplies on vessels and aircraft;
  • Transfer to a foreign-trade zone;
  • Transfer to a customs bonded warehouse;
  • Transfer to a manufacturing bonded warehouse; and
  • Shipment to the U.S. armed forces for use overseas.            

The regulations pertaining to the production of wine are contained in part 24 of Title 27 of the Code of Federal Regulations (CFR), while those pertaining to the exportation of wine are contained in 27 CFR part 28.  For the complete and regularly updated set of export regulations, please visit the e-CFR

Wholesaler’s basic permit requirement

Anyone other than a qualified proprietor of a bonded wine cellar who plans to engage in the business of exporting wine out of the United States must first obtain a basic permit under the Federal Alcohol Administration Act (FAA Act).  The FAA Act requires that anyone purchasing alcohol beverages for resale at wholesale, either domestically or in foreign commerce, to first obtain a Wholesaler's Basic Permit before commencing business.  The application for this permit can be filed using our Permits Online system.   All permit applicants must qualify under the provisions of 27 CFR Part 1

Authorized removals of wine without payment of tax.                  

The provisions of 27 CFR 24.292 and 27 CFR 28.121 provide for the withdrawal of wine without payment of tax from bonded wine premises.  As prescribed by regulation, wholesalers may withdraw wine without payment for:

  • Exportation to a foreign country;
  • Use as supplies on the vessels and aircraft described in 27 CFR 28.21;
  • Transfer to and deposit in a foreign trade zone for exportation or storage pending exportation;
  • Transfer to and deposit in a customs bonded warehouse as provided in
    27 CFR 28.27
    ; and
  • Transportation to and deposit in a manufacturing bonded warehouse.

The provisions of 27 CFR 28.243 provide for the shipment of untaxpaid wine to the U.S. armed forces for use overseas.

Application. 

The regulations in 27 CFR 28.122 provide that a wholesaler intending to withdraw wine without payment of tax from a bonded wine premises as authorized by § 28.121, must file TTB F 5100.11, "Withdrawal of Spirits, Specially Denatured Spirits, or Wines for Exportation", in accordance with the instructions provided on that form. 

TTB F 5100.11 must be approved by an appropriate TTB officer prior to removal of wine.  After TTB approves or denies the application, the wholesaler will be notified by TTB that the wine may or may not be exported.  This process must be completed for each shipment of goods that is exported from the U.S. without payment of tax.

Export marks. 

In addition to the labeling requirements prescribed in 27 CFR part 24, 27 CFR 28.123 requires that the bonded wine premises proprietor mark the word "Export" on each container or case of wine, before the removal from the bonded premises.  Exceptions can be found at § 28.123

Bond coverage. 

In accordance with 27 CFR 28.61, wholesalers withdrawing a specific lot of wine as authorized in § 28.121 without payment of tax from a bonded wine premises must file for bond on TTB F 5100.25 in accordance with the instructions on that form.  In accordance with 27 CFR 28.62, wholesalers withdrawing wine as authorized in § 28.121 without payment of tax on a continuing basis must file for bond on
TTB F 5100.30 in accordance with the instructions on that form.  These bond forms may be obtained through our National Revenue Center at 1-877-882-3277.

Proof of exportation. 

To be relieved of liability for tax, the wholesaler exporting the wine must maintain and submit appropriate and acceptable proof of exportation, which may vary depending on the purpose and final destination of the product.  For details on acceptable proof of exportation, please see27 CFR 28.40, 28.41, and 28.42

Export certificates. 

For information on other export certificates that may be required for exports to certain countries (e.g. Certificate of Free Sale), please visit our Export Documents page.

TTB G:  2010-17
OPR:  ITD
Oct. 06, 2010

Page last reviewed: June 20, 2014
Page last updated: September 16, 2015
Maintained by: International Affairs Division

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