Winery Compliance: Diligence, Deduction and Sleuthery

By Published On: November 15, 2021

For Ann Reynolds, the compliance aspect of the wine business has always fit like a glove. A skill set requiring organization, diplomacy with a slight detective flare for teasing out problems to reach deductive conclusions.

Ann Reynolds

Growing up in the Napa Valley of California, the wine business was part of the backdrop of her childhood. Upon finishing college, her initial plan was to become a teacher, but at that time it was nearly impossible as jobs were scarce.  In the summer of 1993, she applied for a harvest lab technician position at Beringer Vineyards and was hired.  “It took off from there and I never looked back. Opportunity after opportunity kept coming along. The wine business has always been very good to me,” said Reynolds.

In 1998 while at Sterling Vineyards, Reynolds embarked on her first compliance expedition. She was asked to manage a database the winery had implemented, which included entering in work orders, tracking bulk wine gallons, and managing costs.  These different processes and data points required Reynolds to dig in and understand the legal and regulatory rules around these different functions requiring her to be adept and learn winery compliance on the fly. Starting in the cellar was her foundation, but from there, Reynolds would formalize the compliance job function within the winery.

While continuing to work in house compliance for wineries, Reynolds would also start teaching winery compliance at Napa Valley College.  In 2006, Reynolds contacted Steve Krebs, the program coordinator, and told him she wanted to offer a course in winery compliance, which he immediately jumped on and started adding it to the college’s schedule.

“The student interaction was the funnest part. Teaching the course over ten years helped me to dramatically improve my abilities to explain all the ins and outs,” said Reynolds.  “Compliance truly is learning little-by-little.”

One mistake Reynolds sees wineries make is designating the wrong person in the winery for the compliance role.  The right person should be diligent, detail oriented and love record keeping–it is not for everyone.  Additionally once that person is identified, training is paramount.  Compliance consultants need to be shown what kinds of information they need to keep in their records, how to record them as well as how to report the information out.  There are a number of factors including the design of their labels in addition to how the record keeping results in tax impacts for the winery.

From a record keeping task perspective, Reynolds is adamant that wineries need to be on top of their documentation.  She often sees lack of reporting filing details, not calculating their tax reports correctly, or misunderstanding how to calculate their excise taxes to name a few. Not maintaining accurate records can result in suspension or loss of their federal permit or state license.

In the Napa Valley, Reynolds sees unique challenges compared to other parts of California, specifically around the county’s winery permitting process.  There are many hurdles and public pushback as Reynolds has become more worried recently that county commissioners are approving winery permit applications based on the size and annual number of visitors. “This is a concerning trend we’ve been in for many years now. In large part, resulting from a wave of big money moving into Napa county for the wrong reasons if you ask me,” said Reynolds.  “Napa county has essentially been writing the first test case of its kind since the late 1960’s on how many wineries can a relatively geographically small valley have?”

After working at wineries for over 15 years and being exposed directly to designing labels and submitting them to the Alcohol and Tobacco Tax and Trade Bureau (TTB), Reynolds got increasingly frustrated with news stories and blog posts that provided incorrect information. She decided to write a book on the subject titled, The Inside Story of a Wine Label, which is available for purchase on Amazon.  The book is a reference for the wine industry as well as the wine enthusiast that provides a front-to-back perspective as well as the required and non-required items that appear on wine labels in the United States.

Since 2009, Reynolds has been managing her own compliance consulting firm, Wine Compliance Alliance. In addition to consulting services, a core component of her business is winery compliance training.  Earlier this year, she launched the Winery Compliance Training Academy, which will be two online courses (the second one launching at the end of November). This is the first of its kind in the wine world, addressing the void that is real world winery compliance training.  Reynolds hopes to add more courses as the program evolves.

For Reynolds, a key tenet of her winery compliance training is that the recordkeeping behind each wine label should read like a book.  If someone was to look at all of the records, that person should be able to easily follow the story.

About the Author: Joe Campbell

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Located out of the Sierra Foothills of California, Joe Campbell provides color commentary as well as insight within the wine industry both from the lifestyle consumer and business segments of the industry. He can be reached via email at joe at winebulletin.net