Requirements for New TN DTC Licenses and Renewals

Wine Institute has learned that Tennessee has increased enforcement of a regulatory requirement for new DTC licenses and renewals to provide proof of business registration with the TN Secretary of State. We have been working with the TN ABC on this issue and they now intend to amend the direct shipping rules to remove the requirement of Secretary of State registration. It is expected to take up to 90 days to complete the statutorily required rulemaking process. Until the rule change is effective, applicants for new DTC licenses and existing licensees going through the renewal process are required to comply with the TN Secretary of State registration requirement in order for their application to be processed.

Existing DTC licensees are required to complete their renewals within 30 days after their license expires. If the renewal process isn’t completed within that period the license becomes invalid and the winery would have to reapply as a “new” applicant.  Due to fees and business tax obligations associated with Secretary of State registration, some wineries may wish to let their license expire and then apply for a DTC license after the rule change is effective.