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How to export spirits from United States

Exporting distilled spirits from the United States involves manufacturing or sourcing spirits through a federally registered facility and removing them either free of federal excise tax or under a drawback refund scheme. The primary regulatory authority is the Alcohol and Tobacco Tax and Trade Bureau (TTB) under Title 27 of the Code of Federal Regulations (Parts 19 and 28), along with U.S. Customs and Border Protection (CBP) for export clearance. Shipments must comply with federal transfer, bonding, and marking requirements before being cleared through the Automated Export System and exported to destination markets.

Research guide, not legal advice. Compiled October 2026 from the sources listed below.

Licences and permits

  • Distilled Spirits Plant (DSP) Registration and Operating Permit issued by the Alcohol and Tobacco Tax and Trade Bureau (TTB)
  • Federal Alcohol Administration (FAA) Act Wholesaler's Basic Permit issued by the Alcohol and Tobacco Tax and Trade Bureau (TTB) for third-party exporters or brand owners purchasing spirits for export
  • Food Facility Registration issued by the U.S. Food and Drug Administration (FDA)
  • State Distillery License or Wholesaler/Exporter License issued by the relevant State Alcohol Beverage Control (ABC) board or state licensing authority
  • Employer Identification Number (EIN) issued by the Internal Revenue Service (IRS)

Excise and duty on exports

Under 27 CFR Part 28, distilled spirits may be withdrawn from a bonded Distilled Spirits Plant (DSP) without payment of Federal Excise Tax (FET) for direct exportation, transfer to a foreign-trade zone (FTZ), or transfer to a customs bonded warehouse using TTB Form 5100.11 ('Withdrawal of Spirits, Specially Denatured Spirits, or Wines for Exportation'), backed by an export bond (TTB Form 5100.25 or continuing bond TTB Form 5100.30, unless exempt). Alternatively, if spirits have already been taxpaid, the exporter or DSP proprietor can claim a refund (export drawback) of the FET by filing a notice and claim on TTB Form 5110.30 ('Drawback on Distilled Spirits Exported') supported by package gauging records and acceptable proof of exportation under 27 CFR 28.40–28.42.

Documents

  • TTB Form 5100.11 (Withdrawal of Spirits, Specially Denatured Spirits, or Wines for Exportation) for untaxpaid bonded withdrawals
  • TTB Form 5110.30 (Drawback on Distilled Spirits Exported) for drawback claims on taxpaid goods
  • Electronic Export Information (EEI) filing confirmation / Internal Transaction Number (ITN) submitted through the Automated Export System (AES / ACE)
  • Commercial Invoice and Packing List
  • Bill of Lading (ocean bill of lading, inland bill of lading, or airway bill)
  • Proof of Exportation (customs clearance records, landing certificates, or commercial records substantiating export under 27 CFR 28.40–28.42)
  • TTB Export Certificates (Certificate of Free Sale, Certificate of Origin, or Certificate of Age and Origin)
  • Certificate of Analysis (CoA) when required by the destination country

Labelling and certification

Under 27 CFR 28.103 and 28.193, containers and cases must have the word 'Export' marked on the Government side of each case or Government head of each container prior to removal from bonded DSP premises. Distilled spirits bottled solely for export are exempt from mandatory domestic FAA Act labeling regulations (such as domestic TTB COLA approval and standard domestic health warnings), but exporters must satisfy the labeling, language, standard container size, and ingredient declaration laws of the importing country. In addition, TTB provides official certification of origin and age to verify distinctive geographical indications (such as Bourbon and Tennessee Whiskey) recognized under bilateral and multilateral trade accords.

Trade agreements

  • United States-Mexico-Canada Agreement (USMCA) providing tariff-free trade and distinctive product recognition for Bourbon and Tennessee Whiskey in Canada and Mexico
  • U.S.-EU Zero-for-Zero Tariff Agreement (1997 mutual commitment covering distilled spirits trade between the United States and European Union member states)
  • United States-Australia Free Trade Agreement (AUSFTA) providing duty-free treatment for U.S. distilled spirits in Australia
  • United States-Korea Free Trade Agreement (KORUS) providing duty-free access for U.S. spirits in South Korea
  • Bilateral Free Trade Agreements with Chile, Colombia, Singapore, and others providing preferential or duty-free market access for spirits

Government export incentives

  • Market Access Program (MAP) administered by the USDA Foreign Agricultural Service (FAS), providing cost-share export promotion funds to trade associations such as the Distilled Spirits Council of the United States (DISCUS) to promote American spirits internationally
  • Regional Agricultural Promotion Program (RAPP) administered by the USDA Foreign Agricultural Service (FAS), supporting spirits promotion campaigns in emerging global markets
  • American First Trade Promotion Program (AFTPP) administered by the USDA Foreign Agricultural Service (FAS), providing market development and trade show activation funding for U.S. spirits
  • State Trade Expansion Program (STEP) grants funded by the U.S. Small Business Administration (SBA) and administered by state economic development agencies to subsidize export compliance, trade missions, and international marketing for craft distilleries
  • Interest Charge Domestic International Sales Corporation (IC-DISC) federal tax incentive scheme under the Internal Revenue Code providing tax savings on export profits

Main export markets

The primary foreign markets for U.S. spirits include the European Union (notably Germany, France, Poland, Spain, and the Netherlands), the United Kingdom, Canada, Australia, Japan, Mexico, and South Korea, with American whiskeys (Bourbon, Tennessee Whiskey, and Rye) comprising the largest share of export value.

Common mistakes

  • Failing to maintain or submit required proof of exportation (27 CFR 28.40–28.42) within prescribed timeframes, causing TTB to assess domestic Federal Excise Tax and penalties against the exporter's bond.
  • Omitting the mandatory physical 'Export' mark on outer shipping cartons or containers prior to removal from the bonded Distilled Spirits Plant.
  • Non-compliance with destination country packaging and bottle-size regulations, such as shipping standard U.S. 750ml bottles into markets that strictly mandate 700ml containers without obtaining proper variances or labeling corrections.
  • Inadequate tracking of retaliatory tariffs, non-tariff trade barriers, or monopolistic provincial liquor control board restrictions (such as provincial listing barriers in Canada).

Sources

  1. Electronic Code of Federal Regulations - 27 CFR Part 28: Exportation of Alcohol
  2. Distilled Spirits Council of the United States (DISCUS) - Export Promotion & Trade Policy

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