Last reviewed: September 22, 2026
A new winery’s compliance plan begins well before the first label application or government filing. The business model determines which approvals are required, while the property, ownership structure and production arrangement determine how those applications must be prepared. In Napa and Sonoma, local land-use questions can be just as important as state and federal licensing.
1. Define the operating model
Decide who will own the wine, where it will be produced and stored, and which entity will sell it. A traditional bonded winery, an alternating-proprietor arrangement and a brand using custom-crush services are not interchangeable structures. TTB advises businesses to determine whether their proposed activity requires federal qualification before operations begin.
- Who owns the grapes, work in process and finished wine?
- Which entity performs production?
- Will wine be stored or bottled while still in bond?
- Will the company sell at wholesale, direct to consumers, or both?
- Will there be a tasting room, events or off-site storage?
2. Confirm the entity and ownership
Form the operating entity, obtain its tax identification and identify all owners, officers and other principals who must be disclosed. Avoid changing the applicant midway through licensing if possible. Names and ownership percentages should remain consistent across leases, TTB applications, ABC filings and local registrations.
3. Validate the premises before committing
Confirm that the intended use is allowed and that the property can support the licensed operation. Review zoning, use permits, building and fire requirements, wastewater, food-service issues, access and parking as applicable. The lease should provide sufficient control of the areas included in the licensed and bonded premises. Prepare a clear diagram identifying production, storage, tasting, offices and any excluded areas.
4. Map federal approvals
TTB states that approval is required before commercially producing wine, storing or bottling untaxpaid wine, or engaging in covered wholesale or import operations. Determine whether the business needs bonded-winery or bonded-wine-cellar qualification and whether a Wholesaler’s Basic Permit or other authority is also required. Assemble premises, source-of-funds, personnel and signing-authority information before filing.
5. Map California ABC privileges
For an operating winery, the Type 02 Winegrower license is central, but the complete license and permit package depends on what the business will do. Production, tasting, events, direct sales and additional locations should be evaluated as a complete operating plan. Make sure the California application matches the federal premises and entity.
6. Plan products, formulas and labels
Not every wine follows the same approval path. TTB explains that products with added flavoring or coloring commonly require formula approval, and some products may require laboratory analysis before a Certificate of Label Approval application. Evaluate the production method early so formula work does not delay labels, bottling or release. Confirm the class and type, appellation, varietal and vintage eligibility, alcohol statement and other mandatory label information.
7. Design the compliance system before production
- Lot and batch identification
- Grape and wine receiving records
- Production, cellar-treatment and bottling records
- Bulk and bottled inventory by tax class
- Transfers in bond and removals
- Loss, destruction and return documentation
- Federal operational reports and excise-tax workpapers
- California reporting and tax accounts
- License, registration and permit renewal calendar
8. Review routes to market
Wholesale, tasting-room, club, ecommerce and direct-shipping sales can carry different licensing, registration, tax and reporting requirements. Before accepting orders in a new state, confirm the required authority, brand or label registrations, tax accounts, shipment limits, reporting and carrier procedures.
Official starting points
- TTB: Getting started in the wine industry
- TTB federal application process
- TTB formula approval
- California ABC license types
Building a winery compliance plan in Napa or Sonoma? Gateway can help coordinate the federal, California and operational workstreams. Explore winery compliance consulting or contact Gateway Compliance Napa.
This checklist is general educational information, not legal, land-use or tax advice. Requirements depend on the property, ownership, products and sales model. Confirm current requirements with the applicable agencies and professional advisers.