The California Department of Alcohol and Beverage Control recently published an Industry Advisory for Third Party Service Providers (TPPs) (October 2011). TPPs are entities that assist wineries and other licensees with the promotion, marketing and sale of alcoholic beverages by licensees via the Internet or other streams of commerce. TTPs are not licensed by the ABC. The advisory offers guidelines to assist licensees and unlicensed TPPs in complying with the law. The guidelines were developed after the Department held a series of meetings and consulted with industry stakeholders (including Wine Institute) to address the various issues. Ultimately, a licensee is responsible for any activities undertaken by a TPP on the licensee’s behalf and wineries should review the Advisory before entering into relationships with third party providers. Be aware that this advisory only applies to sales made in California, and that some new business plans now allowed in California may not be permissible in all 50 states.
The Advisory is available on the CA ABC website: http://www.abc.ca.gov/trade/IA Third Party Providers.pdf.
