Legal & Compliance Considerations for New Winery Clients
Launching a wine brand involves much more than making great wine. One of the first questions every prospective winery owner should answer is:
How and where do you plan to sell your wine?
Your sales strategy determines which licenses you'll need, how you'll remain compliant, and what ongoing reporting obligations you'll have.
1. Determine Your Sales Channels
Before applying for licenses, decide where you intend to sell your wine.
Examples include:
Direct-to-Consumer (DTC)
Winery tasting room
Wine club
Online sales
Phone orders
Wine shipments
Wholesale Distribution
Restaurants
Retail stores
Grocery chains
Wine shops
Self-Distribution (where permitted)
Events and Festivals
Many wineries use a combination of these channels, and each may require different licenses and compliance requirements.
2. Common California ABC Licenses
Below are several of the most common licenses new winery clients encounter.
Type 02 – Winegrower License
The Type 02 license is the standard California winery license.
It allows a winery to:
Produce wine
Bottle wine
Sell wine directly to consumers
Operate a tasting room (with applicable approvals)
Sell wine to distributors and retailers
Ship wine where legally permitted
Even if your wine is produced at a custom crush facility like Pacific Wine Services, your business typically needs its own Type 02 license to operate as a bonded winery. California and federal regulations also allow wine to be produced at another bonded winery under arrangements such as alternating proprietorships.
Type 17 – Beer & Wine Wholesaler
A Type 17 license allows businesses to wholesale beer and wine to licensed retailers.
This license is generally used by:
Wine distributors
Importers
Wholesalers
If your business model includes distributing products to restaurants or retailers as a wholesaler, you may need this license.
Type 32 – Wine Blender
A Type 32 license is intended for businesses that blend, process, and package wine but do not operate as a traditional wine producer.
These businesses may:
Blend wines
Bottle wine
Package wine
Sell to other licensees under applicable regulations
This license is less common for brand owners and is generally used by specialized wine production businesses.
3. Direct-to-Consumer Shipping
Selling wine online is one thing.
Shipping wine legally is another.
Every state has its own laws governing:
Winery permits
Direct shipping licenses
Excise taxes
Sales taxes
Reporting requirements
Volume limits
Label registration
Consumer age verification
Simply because you hold a California winery license does not mean you can legally ship wine into every state.
Most states require wineries to:
Register before shipping
Obtain a Direct Shipping Permit
File regular reports
Remit taxes
Renew permits annually
Failure to comply can result in fines or the loss of shipping privileges.
4. Every State is Different
Wine shipping laws vary significantly from state to state.
Examples of differences include:
Some states allow unlimited direct shipping.
Others cap the amount of wine a consumer can receive annually.
Some require label registration.
Others require brand registration.
Many have unique tax filing schedules.
Shipping carriers may have additional requirements.
Because these laws change regularly, most wineries work with a compliance professional to stay current.
5. Compliance Professionals We Recommend
Pacific Wine Services does not provide legal or compliance services, but we regularly work alongside experienced compliance professionals.
Jessica Banta Consulting
Jessica assists wineries with:
Federal (TTB) compliance
California ABC licensing
Brand registration
Reporting
Licensing guidance
Regulatory compliance
Nancy – Uncorked Compliance
Nancy and Uncorked Compliance assist wineries with:
State direct shipping registrations
License applications
Excise tax reporting
Sales tax compliance
Ongoing state compliance
Annual renewals
Working with a dedicated compliance professional early in the process can save significant time, reduce costly mistakes, and help ensure your winery remains in good standing.
6. Pacific Wine Services Client Types
Pacific Wine Services works with two primary types of winery clients.
Custom Crush Clients
Custom Crush clients use Pacific Wine Services to produce, age, store, and bottle their wines while operating under their own winery license.
Services may include:
Fruit processing
Fermentation
Barrel aging
Laboratory services
Bottling
Case goods storage
Winemaking support
Harvest logistics
These clients maintain their own bonded winery status and are responsible for their own regulatory compliance and licensing.
Alternating Proprietorship (AP) Clients
An Alternating Proprietorship (AP) allows multiple federally bonded wineries to operate within the same physical winery using shared equipment and facilities while maintaining separate legal identities.
For a growing winery, an AP offers many advantages, including:
Your own bonded winery permit
Your own TTB records
Your own California Type 02 license
Your own wine labels
Independent inventory ownership
Ability to build your own winery brand
Eligibility to sell wine directly to consumers
Greater flexibility as your business grows
An AP is often an excellent option for wineries seeking greater independence without the significant capital investment required to build and operate their own production facility.
Our Recommendation
One of the first conversations we have with every prospective client is about their long-term business goals. Whether you're producing 2 tons or 200 tons, understanding how you plan to sell your wine, where you plan to sell it, and what licenses you'll need helps us connect you with the right compliance partners and structure your production in a way that supports your growth from day one.