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Distillery change of venue


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We moved locations last year, and this is what we had to fill out for the ttb.  All below is direct correspondence from the TTB.


Change in Location (1.41, 19.118)

Amended F5110.41

F5100.18, F5100.25 (as applicable)

Superseding Bond F5110.56

F5000.29 and F5000.30

Copy of lease or proof of ownership

NOTE:  If the company has any case goods in bond that need to be moved to the new location, they’ll need to either tax pay them or request a onetime special permission to transfer them in bond and submit a Change in Bond (Consent of Surety) to cover the transfer. 

A letterhead request for a one-time special permission to movefinished case goods in bond to the new location, it applicable.  The transfer is limited to only those case goods in inventory at the time of the move.


If you have product to move the Change in Bond, Form 5000.18 will refer to the new bond and have this wording:


To extend the terms and conditions of the above bond to cover a change in location from [old premise address] to [new premise address], subject to TTB approval.  Until TTB approves operation at [new premise address], and for 60 days after such approval, bond coverage will also continue at [old premise address].  This consent will also cover the transfer and conveyance of all spirits in bond from [old premise address] to [new premise address] or other bonded facility, no later than 60 days following TTB approval. 

 Change in Bond (Consent of Surety) to cover the one time transfer in bond of finished case goods (beverage spirits only) from the old location to the new, if applicable.




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The TTB advice above is somewhat dated, even if they did give it only a year ago.  

If you filed online originally, then you amend the permit on line as well.  You do not use, and TTB will not accept, paper forms.

You will also need a diagram, which is not listed in the TTB info.

The bond situation is changing, of course, and if you have a bond, you will have to get consent of surety, but it you can get permission to terminate your bond prior to the move, then you would not need the consent of surety - the reason is simple, there would be no surety to give consent.  As a rough guideline, if you pay taxes on 2,000 cases of 80 proof 12/750 bottles, you need a bond; if you pay on less you do not, unless you have some industrial alcohol or, strangely, you pay no taxes at all.  Yup, if you don not pay taxes you need a bond to cover the taxes you do not pay (the withdrawal portion of the unit bond) , plus the potential liability on any bulk spirits you have (the operating portion of the unit bond).  This is not TTB's doing; it is the way that congress wrote the law.  

The issue of moving the cased goods remains because you can't move bottled spirits from one DSP to another, bond or no bond.   So the letter is actually a request for a variance from that requirement, which TTB  will grant on a one time basis.

How long?  Who knows how long TTB will take with anything these days.  Allow five months.  That is a long time to pay two rents.  But do not bank on someone else's experience.  Last year's experience is not this year's experience and someone else's experience this year may not be yours.   I just wrote a client who asked the how long question, giving the same answer and an apology that I cannot give a better one.  

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