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Exporting Distilled Spirits from the U.S. Without Payment of Tax


Distilled Spirits Plant Proprietors Withdrawing Distilled Spirits from Distilled Spirits Plant Premises Without Payment of Tax

The following information addresses the most pertinent regulatory requirements pertaining to distilled spirits plant (DSP) proprietors withdrawing distilled spirits from their DSPs without payment of tax for:

  • Exportation;
  • Use as supplies on vessels and aircraft;
  • Transfer to a foreign-trade zone;
  • Transfer to a manufacturing bonded warehouse;
  • Transfer to a customs bonded warehouse; and
  • Shipment to the U.S. armed forces for use overseas. 

The regulations pertaining to the production of distilled spirits are contained in part 19 of Title 27 of the Code of Federal Regulations (CFR) and the regulations pertaining to the exportation of distilled spirits are contained in 27 CFR parts 19 and 28.  For the complete and regularly updated set of export regulations, please visit the e-CFR.

Authorized withdrawals of distilled spirits without payment of tax. 

The provisions of 27 CFR 19.418 and 27 CFR 28.91 provide for the withdrawal of distilled spirits without payment of tax from DSP premises. DSP proprietors may withdraw distilled spirits without payment of tax for:

  • Exportation to a foreign country;
  • Use as supplies on the vessels and aircraft described in 27 CFR 28.21;
  • Transfer to and deposit in a foreign-trade zone for exportation or storage pending exportation;
  • Transportation to and deposit in a manufacturing bonded warehouse; or
  • Transfer to and deposit in a customs bonded warehouse as provided in 
    27 CFR 28.26.

The provisions of 27 CFR 28.243 provide for the shipment of untaxpaid distilled spirits to the U.S. armed forces for use overseas.


The provisions in 27 CFR 28.92 provide that DSP proprietors wanting to withdraw distilled spirits without payment of tax from their bonded premises, as authorized by § 28.91, must file TTB F 5100.11, "Withdrawal of Spirits, Specially Denatured Spirits, or Wines for Exportation," in accordance with the instructions provided on that form.

Industry Circular 2004-3 provides instructions for DSP proprietors to obtain approval of an alternative procedure that allows them to maintain export documentation at their bonded premises rather than submit the documentation to TTB.  Upon approval, this procedure permits the proprietor to submit monthly summary reports via electronic mail in lieu of mailing specific transaction documents to TTB.  Approval of this alternate method is neither automatic nor guaranteed.  Questions about applying for this alternate procedure are addressed in our FAQs or you may contact TTB at exports@ttb.gov.

Export marks. 

In addition to the labeling requirements prescribed in 27 CFR part 19 , 27 CFR 28.103 requires that the distilled spirits plant proprietor mark the word "Export" on the Government side of each case or Government head of each container, before the removal from the bonded premises.  Exceptions can be found at § 28.103

Bond coverage. 

The provisions in 27 CFR 28.58 require a DSP proprietor’s operations or unit bond given by the proprietor and approved under the provisions of 27 CFR part 19, to cover the withdrawals of distilled spirits without payment of tax authorized by § 28.91

Proof of exportation. 

To be relieved of liability for tax, the DSP proprietor exporting the distilled spirits must maintain and submit appropriate and acceptable proof of exportation, which may vary depending on the purpose and final destination of the product.  For details on acceptable proof of exportation, please see 27 CFR 28.40, 28.41, 28.42 and Industry Circular 2000-2.  If the proprietor applies for and receives approval for the alternate method or procedure outlined in Industry Circular 2004-3, the proprietor may provide proof of exportation as outlined in that Industry Circular. 

Report of DSP premises operations. 

Withdrawals of distilled spirits without payment of tax under § 28.91 should be shown as ‘Exported’ on TTB F 5110.28, "Monthly Report of Processing Operations".

Export certificates. 

For information on other export certificates that may be required for exports to certain countries (e.g. Certificate of Free Sale), please visit our >Export Documents page.

TTB G:  2010-9
Oct. 06, 2010

Last updated: April 1, 2024
Maintained by: International Affairs Division