Alcohol Importer & Winery Export Compliance Guide: TTB Permits, COLA Waivers & Export Certificates

Last reviewed: October 30, 2026

Importing foreign wine, beer, or distilled spirits into the United States—or exporting Napa Valley and Sonoma County wines to international markets in Canada, Europe, the UK, and Asia—requires coordinating federal TTB permits, U.S. Customs and Border Protection (CBP) entries, U.S. FDA food safety filings, and state California ABC importer/wholesaler licenses.

Below is a practical import/export compliance guide from Taylor Marchand at Gateway Compliance Napa.

1. Importing Wine, Beer & Spirits into the United States

Before foreign alcohol can clear U.S. Customs for commercial sale or trade-show sampling, the U.S. importer of record must establish federal and state licensing:

• Federal TTB Importer’s Basic Permit: Issued under the Federal Alcohol Administration (FAA) Act via TTB Permits Online. Applicants must maintain a business office in the United States, pass TTB background and source-of-funds vetting, and provide a foreign supplier letter of intent.
• California ABC Importer & Wholesaler Licensing: To bring imported wine, beer, or spirits into California, an importer must pair its federal TTB Importer’s Basic Permit with the appropriate California ABC license combination—typically a Type 09 (Beer & Wine Importer) paired with a Type 17 (Beer & Wine Wholesaler) (known as a Type 09/17 combination), or a Type 10 (Beer & Wine Importer’s General) license, and for distilled spirits a Type 12/18 or Type 13 (Distilled Spirits Importer’s General) license. (Note: Licensed California Type 02 Winegrowers may also hold a Type 09 Beer & Wine Importer license to import bulk or bottled wine).
• Imported Product COLAs, Pre-Import Approvals & Organic/Origin Certificates: Every imported wine, malt beverage, or distilled spirit requires an approved TTB COLA before customs release, and certain countries/products require TTB pre-import laboratory analysis, sulfite analysis, or certificate of age/origin verification.
• TTB Trade Sample & Festival COLA Waivers: When importing small quantities of non-COLA-approved wines or spirits strictly for trade shows, wine competitions, or distributor tastings, Gateway Compliance Napa prepares and submits formal TTB COLA Waiver Letters so shipments do not get detained at port.
• FDA Prior Notice, FSVP & myTTB CBMA Importer Refunds: Every commercial alcohol import shipment requires an FDA Prior Notice confirmation number prior to arrival, compliance with the FDA Foreign Supplier Verification Program (FSVP), and Foreign Producer registration in myTTB so the U.S. importer can claim quarterly Craft Beverage Modernization Act (CBMA) excise tax refunds.

2. Exporting California Wine & Spirits to International Markets

When a California winery or distillery exports products outside the United States, proper documentation both clears foreign customs and exempts the shipment from federal and state alcohol excise taxes:

• Tax-Free Export Removals (TTB Form 5100.11): Bonded wineries and Distilled Spirits Plants may withdraw wine or spirits without payment of federal excise tax for exportation when properly documented on TTB Form 5100.11 (Withdrawal of Spirits, Specially Denatured Spirits, or Wines for Exportation) and matched with proof of export (such as a signed Ocean/Air Bill of Lading or CBP export record) alongside TTB Form 5120.17 reporting.
• Country-Specific Export Certificates (Certificates of Free Sale, Sanitary/Health & Origin): Many foreign customs authorities in Asia, Latin America, and Europe require official TTB Export Certificates (Certificates of Free Sale, Certificates of Health/Sanitation, Certificates of Origin/Age, or Simplified VI1 documents) before allowing entry.
• Export-Only Label Exemptions: Under 27 CFR § 4.80, wine exported in bond directly to a foreign country is exempt from domestic TTB COLA requirements (provided the labels comply with the destination country’s laws and containers are marked for export).

Streamline Your Import & Export Compliance

Gateway Compliance Napa assists domestic wineries and U.S. alcohol importers with TTB Importer Basic Permits, California ABC Type 09/17 and Type 10/13 licenses, COLA waivers, myTTB Foreign Producer CBMA claims, and international export certificates. Contact Taylor Marchand at Gateway Compliance Napa to get started.

This guide provides general educational information and is not legal or customs advice. Confirm current TTB, CBP, FDA, California ABC, and destination-country requirements prior to shipping.