Illinois Third-Party Provider Rule Signed Into Law

On Friday August 26, Illinois Governor Bruce Rauner signed SB 2989 into law. As we discussed in detail in a previous blog post, this new bill adds a number of new regulations concerning direct to consumer (DtC) wine sales made into Illinois.

To summarize, SB 2989 will require wineries to register with the Illinois Liquor Control Commission (ILCC) the names and addresses of any third party providers utilized by the winery when fulfilling a DtC shipment into the state.

This is only required for parties who will actually handle the wine, though it excludes common carriers, such as UPS or FedEx. But all fulfillment houses will need to be registered. Wineries will need to register these parties when either applying for a new or renewed DtC license.

Further, these third party providers will need to submit an annual return to the ILCC detailing their activities in the previous year.

These changes are part of a broader effort by the ILCC to crackdown on illegitimate DtC sales from unlicensed suppliers and out of state retailers. Tracking shipments coming from third party providers is intended to allow the ILCC to better discern between legitimate and illegal shipments to Illinois residents.

This law will now become effective on January 1, 2017. We are still working with the state to determine how exactly wineries will need to comply with this law once it is in effect, and will make sure to keep you informed as to what we find.

If you have any questions or comments on this new law, please post them in our BevAlc Community.


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