How Florida Distilleries Can Import Bulk Distilled Spirits for Bottling and Distribution

Florida distilleries increasingly look to import bulk distilled spirits for bottling and distribution, whether to expand their own product lines or provide co-packing services to foreign producers. A Florida distillery can serve as its own importer or it can contract with a Florida importer for purposes of bringing bulk spirits into the state.

In either case, the process is highly regulated at both the federal and state levels. Below is a practical guide for navigating these requirements, including when and how excise taxes apply.

Understand Federal Requirements

Before any shipment enters the U.S., the importer (whether the distillery itself or a contract importer) must comply with the federal alcohol regulations, primarily managed by the Alcohol and Tobacco Tax and Trade Bureau (TTB).

Importer’s Basic Permit: Required under the Federal Alcohol Administration Act. Even the importer holds a federal Manufacturer’s or Wholesaler’s Basic Permit, it must have a separate federal Importer’s Permit for bulk spirits. See Alcoholic Beverage Importers: Federal & Florida Licensing.
FDA Prior Notice: Submit prior notice for each shipment through the FDA’s PNSI system. See FDA Prior Notice Required for Imported Alcohol.
COLA (Certificate of Label Approval): Required for each product, even if bottling occurs in Florida. See Label Laws for Florida Beverages.
Bulk Import Restrictions: Federal law generally prohibits importing distilled spirits in bulk except for delivery to a bonded premises of a licensed distiller, rectifier, or authorized bottler. “Bulk” means any container larger than one wine gallon (128 fl oz).

Florida Licensing and Compliance

Florida imposes additional requirements for importing alcoholic beverage products into the state.

State Licensing: A distillery or importer must hold a Florida IMPR license issued by the Division of Alcoholic Beverages and Tobacco (ABT), however an importer that holds a KLD distribution license is not required to have a separate IMPR license.
Primary American Source of Supply: Florida law requires that imported spirits come from a registered primary American source of supply (“PASS”), and each brand must be registered with ABT. The PASS is the manufacturer, bottler, or legally authorized exclusive agent that is the source closest to the manufacturer in the channel of commerce from which an American distributor can obtain the product. A foreign manufacturer or bottler can register as the PASS itself, in which case it will also be the brand registrant. Where the foreign manufacturer or bottler cannot or does not register as the PASS, the importer can apply to the Florida ABT to be designated as the PASS, in which case the importer will be the brand registrant.

Customs and Bonded Transfers

The importer, or its customers broker, must deal with US Customs and Border Patrol (CBP) to ensure that bulk spirit are legally brought into the country and available for delivery to the distillery’s plant.

Customs Entry: File CBP Form 3461 or 7501, indicating delivery to a bonded premises without payment of excise tax. The importer or customs broker must also provide commercial invoices (showing the product description, value, and country of origin), bill of lading, packing list, and customs bond.
Entry Inspections. Shipments are subject to inspection at the port of entry. FDA checks for compliance with labeling, safety, and sanitary standards. Non-compliant shipments may be detained, refused, or destroyed.
Power of Attorney: If a separate importer is responsible for getting the bulk spirits through US customer, it must authorize the distillery to act on its behalf for withdrawal from CBP custody.
Recordkeeping: Maintain CBP entry documents, bills of lading, and DSP records per 27 CFR Part 19.

Excise Tax Obligations

Federal Excise Tax: no tax is due at the point of entry if the spirits are transferred directly to a bonded premises, unlike packaged alcoholic beverage products imported into the US. Tax liability arises only when the product is removed from bond for sale or consumption. This means the distillery pays federal excise tax when bottling is complete and the product leaves bond for distribution.
Florida Excise Tax: State excise tax applies when the spirits enter the Florida distribution chain. Typically, this occurs when the product is sold to a distributor or retailer.

Best Practices for Compliance

Coordinate with a Customs Broker: Ensure they understand bonded transfers and have all necessary documentation.
Maintain Accurate Records: Both TTB and ABT require detailed logs of receipts, withdrawals, and tax payments.
Plan for Timing: Federal and state permits, as well as FDA Prior Notices and COLA approvals, can take weeks to process. Start early to avoid delays.

Final Thoughts

Importing bulk distilled spirits into Florida is feasible but requires meticulous compliance with federal and state regulations. By securing the right permits, following bonded transfer procedures, and understanding when excise taxes apply, Florida distilleries can expand their offerings while staying compliant.

Do you have any questions about importing bulk spirits to Florida? Contact us at to schedule a consultation with a beverage attorney.

Because we’re attorneys: Disclaimer. Updated August 10, 2025.

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