International Commercial Wine Shipping 101!
After a morning of research, because OF COURSE all this information is not in one place, I know now way more than I ever thought possible about: (deep breath)
–TTB COLA!!! (Certification/Exemption of Label/Bottle Approval) waivers. Also, that would be Tax and Trade Bureau, not, as I was hoping, Twin Traction Beam, Test-Tube Baby, or That’s Too Bad. Although I have my suspicions about the last one…hmmmmm.
–FDA Facility Registration and Prior Notice for Shipping: (“Are you now, or have you ever been, a production facility making wine? Oh, ok. Sign here.”) It’s free, easy, and one time only. Yay FDA! And, that would be the Food and Drug Administration, not Federal Disaster Area , Filter Debris Analysis, or First Delivery Attempt. No! WE’RE ONLY GOING TO NEED TO DO THIS ONCE! THERE WILL BE NO SECOND ATTEMPT! (Uh, right guys? Right??)
-The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (Do you think that including the word “bioterrorism” will get my blog flagged by the NSA? 🙂 RELAX GUYS, IT’S JUST FRENCH WINE!!!! Would that be bio-terroirism? 😉
(Terroir is the French word for “sense of place, including soil, climate, etc, that contribute to the particular flavor of a region’s gastronomical products. Bio means “organic” in French.) Wine humor! Joke!
-The FDA Food Safety Modernization Act (FSMA) of 2011
-US labeling requirements (“Contains sulfites” and “Lay off the booze if you’re pregnant”, basically, plus country of origin, grape variety, etc)
(Warning! Wine can give you a beer belly! Or is it a wine belly?…or something?)
-How many Port of Arrivals there are in Ohio (Six. In case you were wondering. Neat-o.)
-FedEx international shipping regulations
-The Ohio Department of Commerce, Division of Liquor Control (Sounds exciting!)
Did your eyes glaze over yet? Did your brain freeze? IS IT POSSIBLE YOU DON’T FIND THIS FASCINATING????
All this to basically ship six bottles of wine as samples to an importer in the U.S! I have an eight page report, a template letter for the importer to obtain the COLA (Certification of Label/Bottle Approval) waiver, and so, so much more. No, really. Try me.
As much as it offends my little anarchist heart to admit, I am actually a rule follower, and I get tremendous anxiety about not doing things by the book. And while I definitely have heard anecdoctal evidence suggesting wine can just tiptoe its way into the U.S, my feeling on it is, why bother? It’s a lot of paperwork, but not really a lot of fees, and while the shipping is expensive (it will be in the hundreds of euros, I think, in the end…I read that assuming about 300€ for a case of twelve bottles of wine is considered reasonable? I find this seriously hard to believe, that our 7€ bottle of wine would get pushed over 30€ due to import tax and regulation, so I’m still doing research.
All this research and paperwork is actually JUST to find an importer willing to carry our wine label, Le Clos d’Elle. Basically, import regulations make it necessary to have a licensed agent in the U.S as an intermediary, who then works with distributors to market and retail the wine in restaurants, wine boutiques, and to private collectors. Wine importers typically have a portfolio of wines, and a focus (for example, high-end Burghundy reds). Finding an importer is HARD.
There’s a lot of reasons for that, but it really comes down to supply (there are a lot of wine makers out there!) and exclusivity. Wine importers can afford to be, and should be, selective, unless your niche is Screaming Uncle Lou’s Hot-DAMN Louisiana Grape-alicious Moonshine, and your target audience is either college freshman or people who are buying and drinking your product out of paper bags.
(I think I got a hangover just from posting that image. Blech.)
It gets doubly hard when you get asked by importers for taste reviews from major magazines like Wine Spectator, who generally will not accept a wine for review unless (you guessed it) you already have distribution in the U.S. Chicken, meet egg.
We’re going to try to get all this stuff done, signed, sealed and delivered before the holidays, so we’ll be in paperwork land tonight and for the rest of the week. And in the end, we’ve more or less figured out how to get a taste review from Wine Spectator, even without representation, so we’ll most likely be trying that too.
Wish us luck! Here’s hoping that in 2014, you, yes you, will be able to purchase your very only bottle of Clos d’Elle wine. 🙂 Cross your fingers!!