Wine and Spirits Logistics: Bonded Moves and Excise Permits

A bulk whiskey tanker arrives at a bottling plant with one dome-lid seal number that does not match the transfer record. The receiving crew, under pressure to free the dock, pumps the load into a receiving tank and notes the discrepancy for later. By the time compliance sees the note, the spirits are commingled, the gauge shows a loss, and the plant has skipped the one step federal rules require before anything leaves that tanker.

Moving wine and spirits under bond is a chain of quantity handovers, each tied to a permit, a seal or a gauge. When every handover compares the same three numbers (permitted quantity, shipped quantity and received quantity) and stops the move when they disagree, losses become explainable events rather than write-offs, and excise exposure stays inside the bond that was approved for it.

• What this guide covers: US transfers in bond under 27 CFR Part 19, untaxed export withdrawals under Part 28, and Indian state excise permits, with Delhi's permit chain as the worked case.
• What it adds: a tanker loss reconciled in proof gallons and USD, a wine consignment reconciled in bulk litres and INR, a receiving incident trace, and a rollout checklist.

What moving alcohol under bond means in the US and in India

In the US, "in bond" means federal excise tax has not yet been paid, and the spirits stay under a TTB-approved bond while they move between qualified premises. In India, liquor is taxed by the states, so the controls that follow a case are state excise permits, with customs bonding as a separate layer for imported product.

TTB's regulations in 27 CFR 19.1 define a transfer in bond as the removal of spirits, denatured spirits and wines from one bonded premises to another. A bulk container is any TTB-approved container holding more than one wine gallon, and the proof gallon is a gallon at 60 degrees Fahrenheit containing 50% alcohol by volume, which is the unit the tax and the losses are counted in.

India's position starts from the Constitution: duties of excise on alcoholic liquors for human consumption fall to the states under Entry 51 of the State List. Section 5(1) of the IGST Act levies integrated tax on inter-State supplies except the supply of alcoholic liquor for human consumption, so the movement documents that matter for a case of wine are the permits each state excise department issues.

TTB Form 5100.16 and the transfer record for bulk spirits

A bulk spirits transfer in bond starts with the receiving plant, not the shipper. The consignee applies on TTB F 5100.16, TTB approves it against the consignee's bond, and only then can the consignor ship under a transfer record that cites the approved application.

Section 19.402 allows bulk spirits and denatured spirits to move between the bonded premises of qualified plants, and wine to move between a bonded wine cellar and a distilled spirits plant in either direction. Section 19.403 has the receiving proprietor complete TTB F 5100.16 in triplicate and send it to the appropriate TTB officer, who will not approve it unless the receiver's bond is in the maximum penal sum or covers the tax and other liabilities.

• Approval copies: TTB returns two signed copies; the receiver keeps one and sends the other to the consignor that will ship the spirits.
• Customs custody exception: transfers from customs custody under 26 U.S.C. 5232 do not need the application.
• Wine exception: an approved TTB F 5100.16 is not needed for wine moving between bonded premises, though a transfer record still is.
• Transfer record content: under section 19.620 the consignor's record carries the serial number and date of the approved application and the consignor's name and plant number.
• Paper with the load: for shipments by truck, the original transfer record and its accompanying documents travel with the conveyance.

A bulk spirits transfer in bond under 27 CFR 19.403 begins when the receiving distilled spirits plant files TTB F 5100.16 in triplicate and TTB approves it against a bond covering the tax; the consignor's 19.620 transfer record must then cite that approval's serial number and date on every tanker.

Seals, gauges and the receipt check on an in-bond tanker

The physical controls are short: the shipper gauges and seals, the receiver checks seals before unloading and gauges again. The rule that operations teams most often break is the order of those receiving steps, because unloading feels urgent and paperwork does not.

Seals on in-bond conveyances need approval by the appropriate TTB officer before use, and the proprietor furnishes and affixes them under section 19.441. The consignor gauges a bulk shipment and records the quantity on the transfer record. At destination, section 19.407 requires the consignee to examine each conveyance and, if seals are not intact, notify the TTB officer immediately, before removing any spirits.

1. Before unloading: compare each seal number on the conveyance with the numbers on the transfer record, and photograph the seals in place.
2. If a seal is broken or different: stop, notify the TTB officer, record the notification time, and hold the tanker without pumping.
3. Gauge the receipt: measure volume, temperature and proof for bulk receipts, and record the result on the transfer record.
4. Record the loss: determine, record and report any loss under the losses subpart, using the shipped and received proof gallons.
5. Acknowledge: sign receipt on the transfer record and keep the original in the receiving plant's records.

The incident from the introduction followed the wrong order. Each timestamp below is from the receiving side of a transfer between two plants, and the controlled version shows the one system change that would have prevented it.

• 9 Nov 2026, 06:30: plant A gauges tank 14 at 3,400 wine gallons and 117.6 proof, applies seals 0045571 to 0045574 and issues transfer record TR-2026-0881 citing its approved TTB F 5100.16.
• 10 Nov 2026, 13:45: plant B's receiving clerk finds 0045578 on the third dome lid, writes "seal mismatch" on the gate log and releases the tanker to pump-off.
• 10 Nov 2026, 15:05: receiving tank R-3 gauges 3,392 wine gallons at 117.4 proof; the load is commingled with an earlier receipt.
• 10 Nov 2026, 16:20: compliance reads the gate log; the TTB officer was never notified before removal, and the 16.19 proof gallon loss cannot be tied to the tanker alone.
• Controlled version: the receiving screen requires seal scans that match TR-2026-0881 or an officer notification reference before it issues a pump-off authorisation.

Proof gallons, transit losses and the tax value at stake

Losses are counted in proof gallons, so every quantity on a transfer must be converted from wine gallons and proof before it is compared. A volume that matches can still hide a proof loss, and a proof that matches can hide a volume loss.

Federal excise tax on distilled spirits is $13.50 per proof gallon at the full rate, with reduced rates of $2.70 on the first 100,000 proof gallons and $13.34 up to 22.23 million proof gallons for eligible producers and importers. Still wine of 16% alcohol by volume or less is taxed at $1.07 per wine gallon before credits. Those rates set the value of a loss even when the spirits are still in bond.

PG        = WG × (Proof ÷ 100)                   proof gallons from wine gallons at 60 °F
Loss_PG   = PG_shipped − PG_received
Loss_pct  = Loss_PG ÷ PG_shipped × 100
TaxValue  = Loss_PG × t                          t = $13.50 full rate; $2.70 or $13.34 where eligible

Shipped : 3,400 WG × 1.176 = 3,998.40 PG
Received: 3,392 WG × 1.174 = 3,982.21 PG
Loss    : 16.19 PG = 0.40% ; tax value at $13.50 = $218.57

India (bulk litres, BL):
BL_received = BL_permit − BL_broken
ExciseValue = BL_broken × e                      e = state duty per bulk litre for that category

India counts differently. The India leg of the worked example counts in bulk litres, the volume printed on a case of bottles, while the duty rate and the unit it applies to are set by each state for each category of liquor. The permit states the quantity authorised, and the receiving licensee's stock register has to show where every litre went.

Freight is small next to the tax at stake. A $2,450 tanker carries spirits worth $53,759.84 in tax at the full rate, which is why seal discipline and dwell time deserve more weight than price per mile when choosing a carrier for in-bond moves. The same logic applies in India, where one broken case can raise an excise question that costs more staff time than the bottle.

Exporting spirits without tax under 27 CFR Part 28

Export is the other common bonded move: spirits leave a distilled spirits plant's bonded premises without tax because they are going abroad. The exporter's paperwork, the plant's marks and the inspection report have to agree before the conveyance leaves.

Section 28.91 permits withdrawals of spirits without payment of tax for exportation, among other purposes, from the bonded premises of a distilled spirits plant, under the applicable bond. Section 28.92 has the exporter file TTB Form 5100.11, which serves as an application when the exporter is not the plant proprietor and as a notice when it is. The carrier to the port of export must be shown on it.

• Package changes first: any repacking for export is done under Part 19 before the form is prepared.
• Inspection and regauge: the proprietor inspects and regauges the packages being withdrawn.
• Export marks: "Export" is marked on the Government side of each case or Government head of each container before removal, and packages carry "EXPORT" under Part 19.
• Inspection report: the proprietor executes the inspection and tax liability report for the withdrawal.
• Certificates of origin: section 28.104 of Part 28 also deals with certificates of origin for exported spirits.

An untaxed export withdrawal under 27 CFR 28.91 and 28.92 requires TTB Form 5100.11 naming the carrier to the port, a plant regauge, and "Export" marked on each case before removal; at $13.50 per proof gallon, a 3,982 proof gallon load carries $53,760 of tax value that the export withdrawal leaves unpaid.

Our guide to foreign-trade zone and bonded warehouse duty reconciliation covers the customs side of goods held under bond in the US, which matters when imported spirits are stored before re-export rather than produced domestically.

Indian state excise permits for liquor crossing state lines

In India each state is a separate excise territory, so a consignment crossing a state line needs permission at both ends: an export permit from the origin state and an import permit or equivalent from the destination. The forms, fees and portals differ by state, which is why a national distributor maintains a permit calendar per state, not one process.

Because the supply of alcoholic liquor for human consumption sits outside IGST, the GST documents that carry most interstate freight do not settle whether a liquor movement is authorised. That job falls to the state permit, and to the stock registers that each licensed warehouse keeps against it.

• Origin state: an export permit from the state the stock leaves, of the kind Delhi issues for liquor sent to other states.
• Destination state: an import permit held by the receiving licensee, as Delhi issues to wholesale licensees for duty-paid liquor from other states.
• Within the state: a transport permit or pass covers movement from a warehouse to retail outlets and licensed premises.
• Imported product: goods stored in a customs bonded warehouse are cleared by an ex-bond bill of entry before the state excise chain begins.

For the customs half of that chain, our page on into-bond and ex-bond bill of entry reconciliation explains how the customs bond ledger is kept. The excise half starts when the ex-bond clearance is complete and the state permit takes over.

Delhi's permit chain from customs bond to retail vend

Delhi's Excise Department publishes a clear permit chain, which makes it a useful worked case. Each permit type covers one leg, and all of them are applied for and processed through the e-Abkari portal.

The table shows the handovers a warehouse system has to model. A case of imported wine can sit under a customs bond, move on a transit transport permit to an L-32 warehouse, then leave on a transport permit to a retail vend. Each leg has its own permit number, and the stock record should carry that number from receipt to dispatch.

Other states use their own forms, licence codes and portals, so the Delhi names do not transfer. What does transfer is the structure: an authorisation per leg, a quantity on each authorisation, and a register at each licensed premises that ties receipts and dispatches to those authorisations.

Delhi's excise permit chain issues transit transport permits for imported liquor moving from a customs bonded warehouse to an L-32 bonded warehouse, import and export permits for interstate stock, and transport permits to retail vends, all through the e-Abkari portal; a warehouse system should match loaded bulk litres to each permit at 100%.

Permit and gauge checks software can lock, and where staff decide

Comparisons between numbers on documents and numbers from scanners or gauges are rules a system should enforce. Readings, judgements about damage and contacts with regulators stay with trained staff, with software preparing the record they sign.

The route-permit problem in heavy haul looks similar but is a different control. Our article on route-survey and permit version control for heavy cargo tracks which version of a road permit matches a trailer configuration; excise permits instead authorise a quantity of a taxed product, so the check here is litres and seals rather than axle loads and routes.

Rollout checklist for a bonded alcohol distribution network

Roll the controls out per site in the order goods arrive: receiving checks first, then dispatch checks, then reporting. A site is ready when every bonded or permitted move it handles can be traced from authorisation to receipt without a paper note.

Bonded alcohol distribution shares its document discipline with customs and heavy-cargo work across our logistics and supply chain library. If you are specifying a warehouse or excise compliance system for spirits, wine or imported liquor, you can outline your sites, states and volumes in our request for proposal form.