Two important pieces of legislation became effective in Maine on Aug. 9, 2024, that will impact the way wineries report certain information to the state. The areas covered are ownership disclosure and direct shipment reporting and the imposition of new requirements on fulfillment houses that provide shipping and logistics services on behalf of a winery direct shipper licensees. Members that ship into Maine may have received preliminary communication from the bureau, but additional guidance is still forthcoming. The Bureau of Alcohol Beverage and Lottery Operations (BABLO) intends to launch a new online reporting system called BELLS sometime this fall. Although the effective dates of the laws have passed, they are dependent upon the implementation of the new reporting system. BABLO has said they will not be requiring any new reporting until the system is launched. Below is the information we have at this time; as more information becomes available, we will keep you informed.
DTC GUIDANCE
BABLO has issued the following document outlining DTC reporting and registration requirements that can be viewed here. Wineries will need to update their software to capture correctly formatted data for shipments that will need to be reported in Jan 2025.
Old Law – DTC licensee reporting:
- Annual reporting corresponded to a direct shipper’s license year.
- Filing deadline for annual reports and excise tax payments was the 30th day of the month immediately following the annual expiration date of the direct shipping license.
New law – DTC licensee reporting:
- Quarterly reporting periods correspond to the calendar year
- First “Quarterly” report using the new template is due Jan. 2025 – It will cover all shipments back to a winery’s last excise tax payment through Dec. 31, 2024 according to the issued-guidance. For example, if a direct shipper’s last excise tax payment covered shipments made through Feb. 28th, 2024, they will need to report shipments from March 1, 2024 through Dec. 31, 2024 in Jan. 2025.
New Requirements for Fulfillment Warehouses:
- Fulfillment houses that provide shipping and logistics services on behalf of a winery direct shipper licensee must obtain a Fulfillment Provider Registration and file quarterly reports. A separate registration and $60 fee are required for each address from which the fulfillment provider will ship wine.
- Direct wine shipper licensees may only use the services of a fulfillment house that has obtained a Fulfillment Provider Registration for the shipping location address.
OWNERSHIP DISCLOSURE GUIDANCE
BABLO has issued two documents outlining their new ownership disclosure requirements, which can be viewed by clicking on the links below:
- Ownership Disclosure Requirements issued 8/9/24
- Supplemental Ownership Form revised 08/24
Wine Institute will continue to work with BABLO regarding disclosure of those that have indirect financial interest, as that portion of the regulations is not clear.