Florida Beverage Suppliers: Meet State Recordkeeping Requirement with 3 Record Types

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Three Key Record Types

Florida alcoholic beverage suppliers–manufacturers, broker-sales agents, importers, and exporters–are required to meet specific recordkeeping requirements under Florida law and regulations. These requirements are summarized below. Meeting these requirements is best done by creating and keeping to following three record types:

Inventory Records should be kept and updated reflecting all products in inventory at a given time. For manufacturers, inventory reports may take the form of production reports, which are updated to show each step in the production process, importantly including final packaging. For importers and exporters that maintain physical inventories, the inventory reports show indicate when products are added to inventory. Broker-sales agents, importers, and exporters that do not maintain physical inventories are not expected to have inventory reports.

Invoices should reflect each sale of products, including the date of sale, the purchaser, the quantity of each brand and container size purchased, the purchase price, and any package deposits charged.

Bill of Lading should reflect each delivery of products to the consignee or an agent of the consignee, including the date of delivery and the quantity of each brand and container size delivered. In many cases, the consignee is the same as the purchaser on an invoice, but not always. For instance, in contract manufacturing arrangements, the purchaser may be another licensed supplier while the consignee–the party to whom the products are actually delivered–is a distributor. Because of this, it is advisable to keep separate invoices and bills of lading, even when they reflect the same information.

Keeping these three record types–inventory records, invoices, and bills of lading–will ensure that Florida alcoholic beverage suppliers have the records they need to comply with Florida’s recordkeeping requirements.

Overview of Florida’s Recordkeeping Requirements

To comply with Florida law and regulations, alcoholic beverage suppliers are generally required to keep records that show the following:

  1. The amount of beverages manufactured or imported into Florida; and
  2. To whom beverages manufactured or imported into Florida are sold (including sales outside to parties outside Florida).

These records must be kept for a period of 3 years at the supplier’s principal place of business. See Florida Statutes Section 561.55.

Florida alcoholic beverage suppliers are required to maintain a principal office in Florida. The principal office must be open for inspection by the Florida Division of Alcoholic Beverages & Tobacco (ABT) during regular defined businesses. See Florida Statutes Section 561.41. Records must be kept in printable form or they must be capable of being printed and reproduced. See Florida Administrative Code Rule 61A-4.011.

Florida exporters, specifically, are required to provide the ABT access to their business premises, inventories, and records, including all records of transporters, warehouses and exporters required by federal law, for the purpose of conducting semiannual audits and inventories.

Overview of Monthly Reporting to the Florida ABT

Its not enough for Florida suppliers to create and maintain records, the also most report periodically to the Florida ABT.

Florida manufacturers, importers, and broker-sales agent are required to report monthly using the ABT’s electronic data submission (EDS) system. See Florida Administrative Code Rule 61-4.009. Monthly reports and excise taxes owed are required to be submitted by 11:59 pm on the 10th day of each month. If the 10th day of the month is Saturday, Sunday, or a state holiday, reporting is due by 11:59 pm on the next following business day.

Exporters do not report to the ABT using the EDS system. Instead, exporters are required to send to the ABT copies that are filed with the federal TTB pertaining to transportation, warehousing and exporting beverage, including all supporting documents. See Florida Statutes Section 561.55(4).

Do you have any questions about Florida’s recordkeeping and reporting requirements? Contact us to schedule a consultation with a beverage attorney.

Because we’re attorneys: Disclaimer. Posted August 28, 2022.

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