Wholesaler & Distributor Licensing

Federally, a wholesaler of distilled spirits, wine, or beer needs a Wholesaler's Basic Permit from the TTB under the FAA Act. Alcohol beverage dealers, including wholesalers, are also subject to registration and recordkeeping requirements under 27 CFR Part 31. But the federal permit is only the start: distribution is primarily controlled by state three-tier laws, so you need a wholesaler or distributor license in each state where you operate, and those licenses carry brand-registration, bonding, and reporting obligations. We file the federal Wholesaler's Basic Permit and build the state distributor licensing for your markets, and we advise on three-tier and franchise-law issues that shape how you can actually buy and sell product.

The three-tier system is the framework most states use to regulate alcohol distribution: producers/importers (tier one) sell to wholesalers/distributors (tier two), who sell to retailers (tier three), who sell to consumers. It generally prevents one company from controlling all three tiers, though states have carved out many exceptions (brewery taprooms, winery DtC, self-distribution caps). For a wholesaler, the three-tier system defines your role: you buy from licensed producers and importers and sell to licensed retailers, and you generally can't skip tiers. The federal 27 CFR Part 31 dealer rules and each state's three-tier statutes govern the details. We help wholesalers understand exactly what their tier permits them to do in each state and structure operations to stay inside those lines.

Franchise laws are state statutes that govern the relationship between suppliers (brewers, wineries, distillers, importers) and their wholesalers/distributors. In many states, once a supplier assigns brands to a distributor, franchise law makes that relationship very hard for the supplier to terminate, often requiring good cause, notice, and sometimes compensation, effectively protecting the distributor. These laws vary dramatically by state and by beverage type (beer franchise laws are often stronger than wine or spirits). For a wholesaler, franchise law can protect your brand rights but also constrains how brands move between distributors. Understanding your state's franchise rules is essential before you take on or give up brands. We advise wholesalers and suppliers on franchise-law exposure and structure brand assignments and terminations to fit each state's requirements.

Yes. While your federal Wholesaler's Basic Permit and 27 CFR Part 31 dealer registration apply nationally, distribution licensing is state-controlled, so you need a wholesaler or distributor license in each state where you take title to and sell product, plus brand/label registrations, and often bonds and recurring reports in each. Some states also have residency or warehousing requirements for licensed wholesalers. The state-by-state licensing, brand registration, and reporting load is substantial and grows with every market you enter. We build and manage the multistate wholesaler footprint: file the distributor licenses, register the brands, set up tax and reporting accounts, and keep the recurring filings current so your distribution stays compliant as it scales.

In most states, yes. Separate from your wholesaler license, states typically require brand or label registration, and often a designation of which wholesaler distributes each brand in each territory, before the product can legally be sold. Brand registration ties the supplier, the brand, and the distributor together under state law and interacts directly with franchise-law protections. Missing or lapsed brand registrations are a common and avoidable compliance gap that can halt sales. We handle brand and label registrations in the states you operate in, keep them current as your portfolio changes, and coordinate them with the franchise-law and territory designations so your right to distribute each brand is properly documented.

Yes. Federally you can hold both an Importer's Basic Permit (27 CFR Part 27) and a Wholesaler's Basic Permit, and act as a dealer under 27 CFR Part 31, letting you import product and sell it at wholesale. At the state level, whether you can perform both roles, and whether you can sell directly to retailers or must use a separate distributor, depends on that state's three-tier rules. Many importers hold wholesaler licenses to control their route to market. We structure the combined importer-wholesaler operation federally and file the state licenses so you can both bring product in and distribute it where the three-tier rules allow.

Wholesalers carry substantial recurring obligations: federal dealer recordkeeping and registration under 27 CFR Part 31, plus state distributor reporting, brand-registration maintenance, bond renewals, and, in many states, monthly or periodic sales and tax reports. You must track what you buy and sell by brand and often reconcile it against state filings. Franchise-law obligations shape how you add or drop brands. Lapses, late reports, an expired brand registration, a missed bond renewal, can interrupt your ability to sell. We manage the recurring federal and state compliance for wholesalers: keep records and registrations current, file the periodic reports, track renewal calendars, and keep everything reconciled so nothing lapses and no filing surfaces a discrepancy.

Yes, multistate distribution expansion is a core service. Entering a new state as a wholesaler means a new distributor license, brand/label registrations, possibly a bond, tax and reporting accounts, and attention to that state's three-tier and franchise rules, all on top of your federal 27 CFR Part 31 and FAA Act permits. Each state has its own forms, fees, and calendars. We determine what each target state requires, file the licenses and brand registrations, set up the reporting, and advise on franchise-law implications of taking on brands there. We also help sequence your expansion so you enter states in an order that fits your supplier relationships and growth plan.