An end-of-year checklist for beverage alcohol sellers

This post has been updated.

Alcoholic beverages are a heavily regulated product, so beverage alcohol sellers must comply with many federal, state, county, and city requirements. Some tasks need to be completed on an annual basis. This end-of-year checklist aims to help beverage alcohol sellers understand and comply with those requirements.

Unlike many other business licenses, beverage alcohol licenses typically need to be renewed and, if necessary, modified every year. This process enables the states to have up-to-date information about each licensee. It also helps ensure individuals with a criminal background don’t obtain a beverage alcohol license, since states generally require all applicants to get a background check.

Fees to renew a license vary from state to state.

License expiration dates differ from state to state. Even within a state, different licenses can expire at different times. In Louisiana, Alcohol and Tobacco Control (ATC) licenses expire December 31 of each year, while Louisiana Department of Revenue licenses expire annually on June 30.

Direct-to-consumer (DTC) licenses must be renewed at the end of each calendar year in several states, including:

• Georgia
• Massachusetts 
• North Dakota
• Oregon

Other states require direct shippers of beverage alcohol to renew their license each year by the first date of issue. In other words, if you first obtained your license in March 2015, you’d need to renew it by March each subsequent year. Still, other states work on different schedules: DTC licenses in Ohio expire annually on October 1.

It’s best to avoid waiting until the last minute to renew your beverage alcohol license. Many states require licensees to submit renewal applications before the license expires, and there may be penalties for late applications. The Georgia Department of Revenue recommends businesses renew before November 1 even though DTC licenses are good through December 31.

Many states now have online portals for license renewals, and where they exist, these are generally preferred over paper renewals. In some states, paper applications are becoming obsolete. The Ohio Division of Liquor Control used to accept both paper and online applications, but it switched to an all online renewal system in October 2023.

On top of annual licensing requirements, states generally have a separate license modification option for beverage alcohol licensees whose circumstances have changed. A license modification is required when a beverage alcohol business changes ownership, location, products, etc. 

It’s good to review your business and modify licenses annually, if needed. It’s even better to work such reviews into your quarterly cycle.

Some states require businesses to register every beverage alcohol product they sell and to renew these registrations annually. Some states have brand registration requirements for wholesale, others for direct ship, and still others for both.

Depending on the state, it may be possible to list multiple products of the same type of alcohol on one application — so your sauvignon blanc could be listed on the same application as your pinot noir. Many states require businesses to submit different applications for different alcohol types: You’d need separate applications for beer products, wine products, and spirits products.

Like licensing requirements, product registration requirements also vary by state. For example, New Jersey product/brand registrations expire annually on December 31; brand registrants may initiate the renewal process on or after November 15 and must submit label renewals by November 30.

Renewal applications in New Jersey cover products registered prior to November 15. Registrations for products registered after November 15 of a year are good until December 31 of the following year. New Jersey allows a bit of a grace period, but products that aren’t renewed as required on or before January 14 will automatically expire.

Brand label registrations in South Dakota must be renewed every year by December 31.

Fees to renew product registrations vary by state and, in some states, by product. In South Dakota, a brand label registration fee is due for each registered product. The initial brand label registration fee for wines is $25, and the additional brand labels registration fee for wines is $17.50 (the law provides for a reduced registration fee when an applicant registers two or more brand labels of the same class of wine). For distilled spirits, both the initial brand label registration fee and additional brand labels registration fees are $50.

Some states, such as Hawaii, don’t charge a fee for product registrations. Others do, and some states that use Product Registration Online (PRO) have a $5 processing fee for each product entry. States that don’t have product registration requirements may still have some kind of rule governing product labels.

Change is a constant in business, especially the beverage alcohol business. As of January 1, 2024, for example, beverage alcohol producers must have a license to ship alcohol directly to consumers in Alaska. (It expires every two years, so any license obtained in 2024 will expire at the end of 2026.) This requirement is relatively new: Beverage alcohol manufacturers could ship to Alaska consumers without a permit prior to 2024. 

It’s best practice to track changes as close to real time as possible, and to review them at the end of each year to determine whether rule or policy changes will impact your annual returns. That’s a big job.

To keep your finger on the pulse of change:

• Check out DTC wine shipping tax rates and rules by state
• Visit the Avalara Tax Desk
• Read Wine Institute state compliance alerts
• Attend a webinar
• Learn more about Avalara for Beverage Alcohol