Three states have added fulfillment house requirements for DTC shippers this year, bringing the total number of states with these requirements to sixteen.

The requirements vary. Some states have established licenses or registrations for fulfillment houses; others require specific reports and/or records from the services; another group simply requires DTC shippers to inform them what fulfillment service they use.

Here are the new requirements for Maine, Nevada and Wisconsin for DTC shippers:

A new law in Maine requires fulfillment providers to register each address from which they ship with the ME Bureau of Alcohol Beverages and Lottery Operations (BABLO). The law also mandates quarterly reporting of wine shipments by direct shippers, fulfillment providers, and common carriers beginning January 1, 2025. The agency only recently began accepting registration applications when its new online licensing system BELLS went live on October 28. Going forward, wineries shipping to consumers in Maine must use fulfillment providers with valid BABLO Fulfillment Provider registrations, and fulfillment providers must keep track of their customer’s ME licenses.

This year Nevada also began requiring licenses from third party logistics companies shipping alcoholic beverages to Nevada wholesalers and/or consumers. The NV Department of Taxation announced in August that all warehouses shipping to Nevada on behalf of suppliers must hold an approved Certificate of Compliance (COC)—the same license held by suppliers and direct shippers. Winery or Supplier applications for new or renewed COCs will not be approved unless the warehouse where the applicant ships holds a valid COC.

Wisconsin will join the list of states regulating fulfillment houses on January 1, 2025. Direct shippers are currently prohibited from shipping to Wisconsin consumers from a third-party warehouse. The new law will allow wineries to use fulfillment houses that hold a WI Fulfillment House Permit. It also will require permits for common carriers shipping wine to WI and monthly reports from both the carriers and the fulfillment houses.

Subscribers to The Digest of Wine & Spirits Law have easy access to updated laws like these. The Digest contains full descriptions of state requirements as well as overview tables allowing a quick review of the primary requirements when shipping DTC or wholesale.

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