Beverage Alcohol Retailers

Registration Requirements

No person may engage in the business of selling or offering to sell distilled spirits, wine, or beer without first registering their business with the Alcohol and Tobacco Tax and Trade Bureau by filingTTB 5630.5d - Alcohol Dealer Registration. You may register as a Retail Beverage Alcohol Dealer in Permits Online. See 27 CFR part 31, subpart E. Registration must be made:

• Before engaging in business.
• For every location of said business.  See 27 CFR 31.112.
• On or before each subsequent July 1, but ONLY IF there has been a change in the existing registration information.  See 27 CFR 31.111 and 27 CFR subpart H.
• Within 30 days of going out of business. See 27 CFR 31.138.

Brewers and proprietors of distilled spirits plants, bonded wine cellars, bonded wine warehouses, and taxpaid wine bottling houses who make sales, whether of their own alcohol beverage products or of such products produced by others, are not exempt from registration and recordkeeping as dealers under this part 31; however,  such persons do not need file a separate form.  Once you apply to establish and operate a bonded wine premises or taxpaid wine bottling house, to register a distilled spirits plant, or to register a Brewer's Notice to establish and operate a brewery, that application or notice will automatically register you as a dealer at that location.   (See 27 CFR 31.48 and, for the dealer registration provisions, 27 CFR 24.52 (wine), 27 CFR 19.202 (distilled spirits), and 27 CFR 25.112 (beer).)

Below is a sample listing of businesses that are subject to registration as a "retail liquor dealer" if they sell or offer for sale alcohol beverage products (e.g., beer, wine, distilled spirits, alcohol beverage coolers, mixed alcoholic drinks, etc.). This requirement applies to on-site consumption and off-site consumption sales. 

Recordkeeping Requirements

Records of Receipt: All retail dealers must keep at their place of business complete records showing the quantities of all distilled spirits, wines, and beer received, from whom the products were received, and the dates of receipt. However, the appropriate TTB officer may, upon request, authorize the maintenance of records at another business premises also under the control of the same retail dealer when it is determined that such maintenance will not cause undue inconvenience to TTB officers desiring to examine those records.  Records of receipts shall consist of all purchase invoices or bills covering distilled spirits, wines, and beer received, or, at the option of the retail dealer, a book record containing all of the required information.  See 27 CFR 31.181.

Records of sales of 20 wine gallons (75.7 liters) or more. Every retail dealer who makes sales of distilled spirits, wines, or beer in quantities of 20 wine gallons (75.7 liters) or more to the same person at the same time must prepare and keep a record of each sale. The record must show the date of sale, the name and address of the purchaser, the kind and quantity of each kind of liquors sold, and the serial numbers of all full cases of distilled spirits included in the sale. Each entry on that record must be supported by a corresponding delivery receipt (which may be executed on a copy of the sales slip) signed by the purchaser or the purchaser's agent.  (Note: Under 27 CFR 31.36, TTB presumes that retail dealers are wholesale dealers if they sell quantities of 20 wine gallons or more, unless they can prove that their customers are not dealers.)

TTB G: 2015-4 
OPR: NRC
Dec. 15, 2015