Alcohol Wholesale License: Federal Permit, State Licensing, and Tied-House Rules

To operate as an alcohol wholesaler in the United States, you need an alcohol wholesale license at two levels: a federal basic permit from the Alcohol and Tobacco Tax and Trade Bureau (TTB), and a separate state wholesale license in every state where you plan to do business. The federal permit is free and has been processing in a median of 33 to 43 calendar days in early 2026, though TTB’s stated customer service goal allows up to 75 days.¹ State licenses carry their own fees, bonds, and timelines on top of that.

What the License Lets You Do

The U.S. alcohol market runs on a three-tier structure that separates producers, wholesalers, and retailers. A wholesaler sits in the middle: you buy from licensed producers or importers and sell to licensed bars, restaurants, and package stores.² Operating in that role without a federal basic permit violates the Federal Alcohol Administration Act and exposes you to criminal penalties and seizure of inventory.³

Who Can Qualify

TTB will not approve your application if you or any officer, director, or principal stockholder of the company has been convicted of a felony under federal or state law within five years before the application date. A misdemeanor conviction under any federal liquor law, including tax violations, within three years before the application date is equally disqualifying.⁴ Those lookback windows apply to every person with a meaningful ownership or governance role.

Beyond criminal history, the statute gives TTB discretion to deny a permit if your business experience, financial standing, or trade connections suggest the business is unlikely to begin operations within a reasonable time or to comply with federal law. A permit can also be denied if your proposed operations would violate the laws of the state where you plan to do business.⁵ You should have your state licensing underway, or at least mapped, before TTB reviews the federal application.

The Federal Application

The federal wholesaler permit application is built around TTB Form 5100.24, which collects detailed information about your business entity, its principals, and the types of alcohol you plan to distribute.⁶ You file it electronically through TTB’s Permits Online portal.⁷ Before you file, you need an Employer Identification Number from the IRS. Alcohol wholesalers fall under businesses required to pay excise taxes, so the EIN is a prerequisite, not a formality.⁸

Along with Form 5100.24, TTB requires supporting documents depending on your business structure:

Proof of signing authority. For corporations, an excerpt from the Articles of Incorporation or TTB Form 5100.1. For LLCs, an excerpt from the Articles of Organization. For partnerships, an excerpt from the partnership agreement. Meeting minutes or a board resolution showing signing authority also work.⁹
Power of Attorney on Form 5000.8, if anyone other than a listed employee (such as an outside attorney or consultant) will sign documents or correspond with TTB.⁹
Personnel Questionnaire on Form 5000.9, for any principal who is a citizen of a foreign country, has lived abroad for more than two years after turning 18, or has association with a foreign country. The form asks about criminal history going back ten years for misdemeanors.¹⁰
Foreign supplier documentation, if you also plan to import. A contract or letter of intent from the foreign supplier confirming they will supply you once the permit is issued.¹⁰

Every principal listed on the application must provide a Social Security number and consent to a background investigation. TTB verifies the accuracy of everything submitted. There is no federal filing fee.¹⁰

State Licensing on Top of the Federal Permit

The federal basic permit does not authorize you to operate on its own. Every state has its own alcohol control board or commission that issues separate wholesale licenses, and the requirements vary widely. Annual state license fees range from as little as $25 to over $4,000 depending on the state and the category of alcohol you plan to distribute. Many states also require a surety bond to guarantee payment of state excise taxes, with minimum amounts running from $1,000 up to $1,000,000 for high-volume distributors.

State applications typically require background checks, financial disclosures, proof of warehouse facilities, and evidence that your planned location meets local zoning requirements. Some states impose residency requirements for owners or officers. Others cap the number of wholesale licenses available. Contact your state alcohol control board early. TTB itself instructs applicants to meet all state and local requirements as a condition of federal approval.¹⁰

FDA Food Facility Registration

If you plan to warehouse the alcohol products you wholesale, the Bioterrorism Act of 2002 requires you to register with the FDA as a food facility. Alcoholic beverages fall under the FDA’s definition of food for registration purposes.¹¹ Registration is free and submitted through the FDA’s online system. You provide the facility’s name and address, the owner or agent in charge, an emergency contact, and the food product categories you handle. TTB lists this as a filing requirement on its own wholesaler application page, so skipping it puts your federal permit at risk.¹⁰

Warehouse Requirements

Your storage facility must be a dedicated commercial warehouse, not a residential property. At the federal level, the application collects premises information through Permits Online, and an investigator may visit before approval to verify the space. State documentation is usually more detailed. Expect to submit a lease agreement or deed proving you control the property, a floor plan showing receiving, staging, and storage areas, and a certificate of occupancy or zoning approval from the local jurisdiction.

Controlled access, surveillance systems, and clear separation between alcohol storage and any other activity in the building are standard expectations. If an inspector finds the facility doesn’t match what you described in the application, approval stalls until the discrepancy is fixed. Getting the warehouse inspection-ready before filing saves weeks.

Timeline and What Approval Looks Like

TTB’s customer service goal is to process 85% of original permit applications within 75 days. Wholesaler applications have been moving faster in practice: the median was 43 calendar days in January 2026 and 33 days in February 2026.¹ State timelines vary and often run longer. During the review window, a TTB investigator or state agent may schedule a walk-through of your warehouse. Final approval notifications typically arrive through the online portal or by email.

Tied-House Rules You Need to Know Before You Operate

This is where new wholesalers get into trouble most often. Federal law prohibits wholesalers from creating financial ties with retailers that could influence purchasing decisions. The rules, collectively called “tied-house” restrictions, are broader than most people expect.² As a wholesaler, you cannot:

Hold any interest in a retailer’s license or property. This includes partial ownership, mortgages on a retailer’s premises, and renting display space in a retail store.
Give things of value to retailers. Equipment, fixtures, signs, supplies, money, or free services are all prohibited unless a narrow regulatory exception applies.
Pay for advertising or displays. Cooperative advertising with retailers, paying for display setups, and reimbursing retailers for promotional activities all violate the rules.
Extend credit beyond 30 days from delivery date. Longer credit arrangements are treated as unlawful inducements.
Require quota purchases or tie-in sales. You cannot condition the sale of one product on the retailer’s agreement to buy another.²

Violations lead to permit suspension for a first offense and revocation for subsequent offenses. TTB also accepts settlement payments known as Offers in Compromise as an alternative to suspension, and the amounts can be large. Historical settlements have reached $2,500,000 for exclusive outlet and tied-house violations. Even a single misdemeanor conviction for a trade practice violation carries a fine of up to $1,000 per offense. The standard for violation is “exclusion,” meaning the practice placed the retailer’s purchasing independence at risk, whether or not it actually prevented a competitor’s sale.¹²

Recordkeeping After Approval

Once your permit is active, the compliance obligations begin. Wholesale dealers in liquors must keep daily records of every receipt and disposition of distilled spirits. When TTB requests it in writing, you also prepare and file a monthly summary report totaling those daily transactions, due by the 15th of the following month. If you had no transactions during a given month, you still file the report marked “No Transactions During Month.”¹³

For wine and beer, the obligation is lighter. You keep a complete record of quantities received, who supplied them, and the dates. Purchase invoices satisfy this. No periodic reports to TTB are required for wine and beer transactions.¹³ All records must be retained for at least three years from the date of the record or the last required entry, whichever is later. TTB can extend retention by up to three additional years if it deems the extra time necessary for revenue protection.¹⁴

Reporting Ownership and Control Changes

A federal basic permit is not transferable. If your company undergoes a change in ownership, or a change in who controls the majority of voting stock or membership interest, you have exactly 30 days to file an application for a new basic permit with TTB. File within that window and the existing permit stays in effect while TTB reviews the new application. Miss the deadline, and the permit terminates. Wholesale operations must stop until TTB approves a new application.¹⁵

The same 30-day rule applies to changes in actual control, meaning a new person takes over day-to-day management even if the ownership structure stays the same. A change in entity type, such as converting from a sole proprietorship to an LLC, counts as a change in proprietorship and triggers the same filing requirement.¹⁵ Your permit can also be revoked if you fail to engage in any wholesale operations for more than two years, or annulled entirely if TTB discovers the original application contained fraud or a concealed material fact.⁵ Keeping the permit active means using it and keeping TTB informed when the business changes.

1
Alcohol and Tobacco Tax and Trade Bureau. Processing Times for Original Permit Applications
2
eCFR. 27 CFR Part 6 – Tied-House
3
Alcohol and Tobacco Tax and Trade Bureau. Liquor Laws and Regulations for Retail Dealers
4
eCFR. 27 CFR 1.24 – Qualifications of Applicants
5
Office of the Law Revision Counsel. 27 USC 204 – Permits
6
eCFR. 27 CFR Part 1 – Basic Permit Requirements Under the Federal Alcohol Administration Act
7
Alcohol and Tobacco Tax and Trade Bureau. Applying for a Permit and/or Registration
8
Internal Revenue Service. Employer Identification Number
9
Alcohol and Tobacco Tax and Trade Bureau. Wholesaler – Importer Required Documents
10
Alcohol and Tobacco Tax and Trade Bureau. Permit Application
11
U.S. Food and Drug Administration. Guidance for Industry – Registration of Food Facilities
12
Alcohol and Tobacco Tax and Trade Bureau. Federal Trade Practices – What Every Industry Member Should Know
13
eCFR. 27 CFR Part 31 Subpart J – Wholesale Dealers Records and Reports
14
eCFR. 27 CFR Part 19 Subpart V – Records and Reports
15
Alcohol and Tobacco Tax and Trade Bureau. Changes in Proprietorship and Changes in Control for Wholesalers and Importers