Arizona's Direct to Consumer Shipping Rules - An Exercise in Complexity

Many wineries that ship direct to consumer (DTC) in Arizona have received compliance notices from the AZ Dept. of Liquor Licenses and Control (DLLC), seeking to audit how much wine they produce to assure compliance under Arizona’s byzantine DTC laws. 

What’s going on in Arizona?

People are wondering, what’s going on in Arizona? According to the DLLC the step-up in enforcement is due to a recently-implemented new reporting mechanism developed with input from the industry to make it easier for wineries to do their reporting (which is not a new requirement), and for the state to track that reporting.  To streamline the process, reporting is now done online (via this page).

Arizona has the dubious distinction of having some of the most complicated direct shipping rules in the country.  We thought it might be helpful if we broke them down and made them a little easier to understand for non-Arizona wineries (and tiny distillers – you too can ship direct!):

The Production Requirements – What are they?

The bottom line is that the amount of alcohol produced per calendar year by the licensee with the permit is the basis for the Arizona direct shipping rules.  It’s best to be a very small winery, and the requirement to be licensed is measured on a facility by facility basis. Each individual winery (regardless of common ownership by a parent company) counts as one permittee.  If the winery produces between 200 gallons/year and 20,000 gallons/year and obtains an Out of State Farm Winery license from the DLLC, the winery will be allowed to ship any amount of wine that the winery produces or manufactures to an Arizona individual, regardless of whether they purchased the wine in person at the winery, or over the Internet, phone or other method.  Wineries in this category are also allowed to sell direct to trade (i.e. to Arizona retailers, both on- and off-premise). 

Craft Distillers are included in the DTC program

Small craft distillers may take advantage of this privilege:  A craft distiller producing no more than 1,189 gallons/year (and obtaining an Out of State Craft Distillery license), may ship any amount of their products directly to AZ residents who order it via Internet or any other method, as well as directly to AZ retailers. This is an important privilege.

What about the larger wineries?  Now it gets confusing. The 8,333 to 16,600 case winery restrictions

It a winery produces between 20,000 and 40,000 gallons (16,666 9L cases of wine) per year, it is still eligible for a Farm Winery permit, but the winery can only ship its wine to an Arizona resident who had at some point visited and made an in-person purchase at the winery with the permit, and the winery is limited to shipping 2 cases per individual per year.  The winery must keep records that can back up the in-person visit, such as a signature and ID-verification in a logbook, etc., as Arizona requires such records to be kept for two years.   This is where the audit comes into play, as the state audits the production limits, the visit requirement and 2 cases per year requirement.

How about the big wineries, can they do anything?

Yes. Although wineries that produce over 40,000 gallons/year are not eligible for the Farm Winery Permit, if they hold any other license in Arizona (such as an Out of State Producer license for shipping to Arizona wholesalers), they don’t need any additional license in order to ship DTC, though they still must follow the in-person purchase rule and the 2-case per person per year rule.

This is important: The DLLC interprets the in-person purchase requirement to mean that the person must visit the winery, at some point (and the winery must have records to back this up), but does not require that person to place each subsequent order in-person at the winery. The winery is required to keep records for two years, but in order to keep shipping directly to a person beyond the two-year period, the winery would need to have a record of that person's on-site purchase (which may reach back more than two years). Again, this is subject to audit.    

General Requirements

For all of the direct shipment methods described above, age verification at time of purchase is required.  Additionally, products cannot be shipped to a licensed premises but only to an individual for personal use; the delivery person must be at least 21; and the packaging must contain language identifying the contents as alcohol and that an adult signature is required.  And last but not least, shipment reports are required from both the shipping winery and the carrier that shipped the product.

Finally, the Arizona Direct Shipment Permit

And finally, there is what’s called a Direct Shipment permit in Arizona – but it’s not at all what it sounds like, and is a last resort.  It is for any winery that holds no other licenses in Arizona and wishes to ship DTC to consumers who have not visited the winery in person. It allows an out of state winery to take orders via Internet or any other method from and ship to a consumer, but the shipment must go through an Arizona wholesaler and retailer, and the retailer must be the one who makes the delivery to the consumer.  Cumbersome? Yes.  Does anyone do this?  Probably not many large wineries take advantage of this dubious solution.

What’s next?

There are rumblings that the confusing DTC situation in Arizona may be cleared up with legislation next year, so stay tuned.  However if you get an audit letter, read this blog post (and the requirements in the audit letter) carefully and make sure that you are eligible for the shipping method that you are using.  Failure to properly comply carries potentially serious consequences.

 

Sweeping Changes in Proposed NYSLA Bill Include Expansion for Craft

The New York State Liquor Authority has been busy working on a series of statutory revisions that are intended to revise and streamline the provisions of the NY ABC law governing manufacturing and wholesale licenses. Retailers will also be affected. The SLA plans to submit the proposals to the Governor (who has announced he will be introducing a bill this session to address supplier issues) for his consideration, and held a meeting on April 17 to get input from the industry on the proposed revisions. Stay tuned for an update on the final outcome of this process because the politics and the lobbying from all sides may be fierce; especially over provisions softening the three-tier system in NY.  In the meantime, here are some highlights from the 122-page proposed legislation in its current form:

DTC:  Direct to consumer shipment rights would be extended to craft brewers and craft cider producers.  In addition, any producer with a NY direct shipping permit (winery, brewery or cider producer) would be able to ship products produced by others, in addition to their own, so long as those other producers were located within a 50-mile radius of the shipping producer. The 50-mile radius requirement is interesting because, for example, it would bring most (if not all) of Napa and Sonoma, for example, into the shipping radius for one winery.

Supplier Tastings: The bill would expand the categories of applicants eligible for marketing permits, which allow the holder to conduct tastings and bottle sales at other locations, to certain suppliers and “brand owners.”  Licensed wholesalers and importers would be allowed to obtain a “distributor’s tasting permit” for consumer tastings. “Brand owner” is not defined in the current version, and is likely to spark a battle if it includes, for example, foreign producers, celebrities, and non-producers.

Special Events: Manufacturers and “brand owners” would be able to obtain a permit to sell wine, beer or cider by the glass at special events.

Retailer Tastings:  Grocery stores licensed to sell beer would be able to conduct consumer beer tastings, though all beer poured must be from kegs, not bottles or cans. (The keg requirement was apparently intended to provide some assurance to certain local jurisdictions that have experienced problems with open container violations, though the SLA did indicate that it could be changed down the road if grocery beer tastings go smoothly in the interim).

Wine Growlers:  Retailers would be able to sell wine in growlers.  There is no indication yet how the legislation would address the fact that the TTB currently requires a federal basic permit as a tax-paid bottling house for a retailer to sell growlers; perhaps there would be an exemption provided in the final enabling legislation.

The significance of these proposed measures lies in their potential effect on the three-tier system, not just in NY but in every state that looks to NY for guidance.  Will the proposed changes be viewed by the distribution tier as an attack on their privileges, or as reasonable measures designed to facilitate routes to market for small producers?

Build It and They Will Come: Craft Products Get New Privileges in CA and TX

Big news for craft producers in California and Texas, two of the biggest consumer markets in the United States: Texas craft brewers and distillers now have expanded retail sale and on-sale consumption privileges and California craft distillers have expanded tasting privileges as a result of newly enacted legislation.  But why does this matter?  Why is it important to give craft producers more control over the experience consumers enjoy on their premises? While now such an essential part of California culture, it is almost hard to remember that the big business of California wine country tourism is a relatively new phenomenon.  It was less than forty years ago in 1976 that the Judging of Paris famously put California wine on the global map and helped shape what is now the fourth largest wine-producing region in the world.  The demand for California wine in the 1970’s fueled rapid growth and the number of wineries in the state ballooned from 227 in 1966 to more than 3,400 in 2010, according to the Wine Institute.  Strength in numbers and burgeoning state revenue created a powerful lobbying force, and California wineries pushed for legislation to give wineries broad privileges to allow consumers to experience California wine country by tasting and buying wine directly from the beautiful winery properties for both on-premises and off-premises consumption (and later, the privileges of shipping directly to consumers, but that’s another bedtime story).  Other states soon followed suit, and wine countries popped up across the country, to give the new American wine consumer access to small producers who didn’t have mass distribution in America’s retail establishments.

But under an alcohol regulatory system in which everything is prohibited unless expressly permitted, these tasting and retail privileges did not always extend to local brewers and distillers, whose sectors were dominated by the mass-produced national and international brands, most of whom did very well through the traditional three-tier system and had little interest in bringing consumers to experience their production facilities.

As craft breweries grew in popularity in the 1980’s, California granted the same privileges to local breweries, brewpubs and microbreweries to conduct on-premise tastings and sell to consumers for off-premises consumption.  See Cal. Bus. & Prof. Code § 23357.  We’ve since seen a massive explosion of craft beer that just keeps growing at exponential rates across the country.  The Brewers Association estimates the number of craft brewers to have grown from 8 in 1980 to 537 in 1994 to over 2300 in 2012, with more than 1500 in development around the country.

As a sign of this ever-expanding growth, earlier this year Texas expanded the privileges of brewpubs and microbreweries to permit consumers to tour and taste at the licensed premises and to permit expanded routes to market for small brewers:

  • Brewpubs can manufacture up to 10,000 barrels annually instead of 5,000 and can sell to distributors and up to 1,000 barrels to retailers, in addition to consumers who visit their premises (SB 515).
  • Brewers and manufacturers who sell less than 125,000 barrels can self-distribute up to 40,000 barrels directly to retailers (SB 516 and SB 517).
  • Brewers and manufacturers who produce less than 225,000 barrels annually can sell up to 5,000 barrels of malt beverages produced on the premises for on-sale consumption to consumers (SB 518).

See TABC Press Release, “New craft beer laws signed by Governor Perry, go into immediate effect,” available at https://www.tabc.state.tx.us/home/press_releases/2013/20130615.asp

Craft spirits are growing too, especially with Millennials, who can be seen across the country in bars ordering exclusive specialty cocktails prepared by mixologists, key influencers for growing small batch brands.

As a result of this growth in craft spirits, this year Texas also opened up its laws to include local distillers and rectifiers, who are now able to sell or give away samples of their products to consumers for on-sale consumption up to 3,000 gallons annually, and sell up to two 750ml bottles of their products every thirty days to a consumer who visits the premises, up to 3,500 gallons annually. (SB 905).

This year in California, Governor Brown signed AB 933, which will permit distilled spirits manufacturers to charge each consumer for up to six ¼ ounce tastes of the distillery’s own products on its licensed premises.  The bill will become law in January, meaning distillers will be able to begin charging for tastings, without the necessity of using a work-around protocol like charging for glassware but not the tasting.

It is worth noting that AB 933 does NOT permit distillers to charge for or provide mixed drinks as part of the tastings, specifically stating that these tastings “shall not be given in the form of a cocktail or a mixed drink.”  This is an unfortunate restriction because it deprives consumers of the ability to taste the distilled spirits in the form they are most likely to consume it—in a cocktail.  Moreover, in our current cocktail culture, many distilled spirits manufacturers have very specific drink recipes and mixer recommendations intended for their products that they will not be able to share with consumers on site as part of these tastings.

Additionally, while neither current California law nor AB 933 will permit California distilled spirits manufacturers to sell bottles of their products directly to consumers from tasting rooms—all products will be required to be sold from a retail-licensed premises through the three-tier system—we hope this privilege will not be far behind, despite strong opposition from the distribution tier.

Will craft beer and spirits follow the example set by the American wine industry?  If you build it, will they come?  We hope that the expanded experiential marketing and retail sale privileges that helped the American wine industry tell its story to consumers will now extend to the craft beer and spirits industries, giving consumers the opportunity to fall in love with more small, local and creative brands than ever before.

For more information about craft beverages, please check out the Craft Beverage Expo in May 2014 in San Jose, California.  Hinman & Carmichael’s Rebecca Stamey-White serves on the Advisory Board.

The New York SLA and Online Wine Sales: A Work in Progress

On April 9th, the New York State Liquor Authority (SLA) issued a declaratory ruling describing limits on the activities of national advertisers (marketing websites) who advertise the availability of wine for sale to consumers in New York from licensed NY retailers. While the system presented to the SLA was not the first Internet marketing platform designed to operate within the three-tier system in New York (and to attempt to comply with all of the NY laws and regulations associated with selling wine through the three-tier system), it was the first time anyone had requested a declaratory ruling from the SLA to obtain guidance on how to operate such a marketing platform.

In its eight-page ruling, the SLA analyzed an actual relationship from an earlier iteration of the model that was submitted to the SLA for the declaratory ruling. The SLA noted that the relationship did not comport with the model presented to the SLA for approval (that was because the relationship existed before the model was developed and submitted), and found that the historic day-to-day business relations between that Internet advertiser and that NY retailer violated ABCL §111, which “prohibits a licensee from making its license available to a person who has not been approved by the Authority to hold that license.” In other words, the SLA believed the advertiser in the relationship they examined was too involved with, and had too much control over, the retailer’s business.

This is far from the death knell of Internet wine marketing platforms in New York; indeed, the SLA went out of its way to acknowledge that the Internet, and Internet marketing, is of vital importance to the NY marketplace.  In announcing its ruling, the SLA said it will continue to conduct public meetings and gather more information to further address the issues raised by the more sophisticated model described in the declaratory ruling request, as well as more generally, the issues raised “by the involvement of unlicensed parties in the Internet sale of alcoholic beverages to consumers in this state,” in an Advisory to the trade.

In the meantime, there are a number of important takeaways in the ruling itself that provide helpful interim guidelines to Internet wine marketers and NY retailers.  According to the SLA, a third party advertising arrangement with a licensed NY retailer selling wines through the three-tier system should abide by the following guidelines:

(a) Flat fees to retailers (paid by the Internet advertiser to compensate for a sale) are prohibited;

(b) Advertisers may not decide what wines will be offered for sale by the NY retailer (this is a function reserved to the retailer);

(c) Advertisers may not set the website prices for the wines offered for sale by the NY retailer (this is a function reserved to the retailer);

(d) Advertisers may not perform essential retailer functions such as deciding how consumer funds are controlled and disbursed, and deciding what the retailer’s profit margin will be; and

(e) Advertisers may not retain a “substantial” portion of the sales price for their services.

Thus, a retailer who selects the products that are going to be advertised on its behalf, sets the prices for the products that are going to be advertised, determines and receives normal business margins for the products that its sells, controls the funds received from consumers, and takes normal business risks (for example from loss or breakage of product, or credit card fraud) may utilize Internet advertising services facilitated by third parties.  (These elements were all present in the advertising platform described in the request for declaratory ruling, but the SLA focused on the prior system in its ruling).

There were also some unquestionably safe harbors mentioned by the SLA as a precursor to its Advisory to come:  a third party may host and maintain a retailer’s website and perform "related services," and a retailer may advertise its own products on a third party’s website, so long as consumers are directed to the retailer's website to place orders and the advertiser’s compensation is a flat fee that is "not contingent on the number of sales or the amount sold.”

While this ruling answered some questions, it raised many others that still need to be addressed - such as, is it acceptable for an advertising and marketing fee to be something less than a substantial portion of sales made by the retailer, or must it always be a flat fee?  What kinds of banking arrangements may the retailer use to receive consumer funds?  To what extent may a retailer coordinate with an Internet advertiser who is running a national advertising program? These are all tricky questions and we look forward to further guidance on these issues from the SLA.

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