TTB Required Biannual Physical Inventories of Finished Products

Are you conducting your TTB required physical inventories of your Finished Products twice a year?

The TTB requires all distilleries to take a physical inventory of bottled spirits twice a year to coincide with the Excise Return Periods ending June 30th and December 31st per 27 CFR § 19.372. The TTB does allow distilleries to perform these physical inventories on dates other than June 30th and December 31st if certain conditions are met (see below). The TTB can also waive the requirement for two physical inventories each year, but formal approval must be granted from your TTB Agent before distilleries are exempted and the waiver can be reimposed if the TTB deems it necessary. See the below excerpt from 27 CFR § 19.372 for easy reference:

After your team completes a physical inventory of your bottled spirits, you should make inventory adjustments as needed to any incorrect DISTILL x 5 Finished Product inventories (see Dx5 Support Article here for more information). Users can also upload PDF/Excel files of their physical inventory data to their DISTILL x 5 Files Portal (Admin > Files > Add New File), if desired. Doing so will help keep your records in the 'cloud' and can be easily retrieved in the event of an audit.