Direct to consumer (“DTC”) wine shipping is a reoccurring topic on the Alcohol.law Digest. (Our most recent post on winery and retailer DTC shipping is located here.) This particular post addresses recent legislation in Connecticut, Senate Bill 647. Effective today, that legislation creates a new permit allowing out-of-state retailers to sell and ship wine directly to Connecticut consumers. The Connecticut Liquor Control Division has posted the application for this new permit, the Out-of-State Retailer Shipper’s Permit, as well as application instructions and guidance, here.
The compliance requirements for the new permit mirror the existing requirements for wineries to ship directly to Connecticut consumers. For example, out-of-state retailer shipper permittees must ensure that wine containers are conspicuously labeled: “CONTAINS ALCOHOL—SIGNATURE OF A PERSON AGE 21 OR OLDER REQUIRED FOR DELIVERY.” Further, the wine recipient must sign for the delivery and provide valid proof that he or she is at least twenty-one years of age. There are registration, reporting, and tax obligations. An out-of-state retailer shipper permittee may not ship more than five gallons of wine to the same Connecticut consumer in any two-month period. Additionally, there is also a new requirement, applicable to out-of-state retailer shipper permittees as well as out-of-state winery shipper permittees, that prohibits the sale of wine below cost. Finally, the Connecticut LCD guidance indicates that all wine brands that will be shipped to Connecticut consumers must be registered with the state.
If you have any questions about direct to consumer shipments of alcohol, contact one of the attorneys at Strike & Techel.
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