Don’t Ruin Your Holiday Spirits—File Your Quarterly Reports Now!
As fall approaches, Pennsylvania distilleries and manufacturers are reminded that compliance deadlines are fast approaching. The year-end holiday season should be a time of celebration, but missing mandatory filings with the Pennsylvania Liquor Control Board (PLCB) could create complications, delay renewals, and jeopardize your license going into 2026. Staying ahead of these requirements ensures your business remains in good standing while you keep your focus on production and growth. Quarterly reports are new this year, as the laws went into effect too late in the 2024 calendar year for the PLCB to update their systems.
Act 86 and Ready-to-Drink Cocktails
On July 17, 2024, Gov. Shapiro signed into law Act 86 of 2024, more commonly known as the Ready-to-Drink Cocktail Act (RTDCA). Effective Sept. 16, 2024, Act 86 formally recognized Ready-to-Drink Cocktails (RTDCs) within Pennsylvania’s Liquor Code. RTDCs are defined as pre-mixed distilled liquor beverages packaged in containers of up to 16 ounces, with alcohol content ranging between 0.5% and 12.5%. They are classified as liquor, and importantly, do not include wine, beer, or malt beverages.
Since Act 86’s passage, both limited and full-scale distilleries across the Commonwealth have seized new opportunities to produce more than 300+ varieties of RTDCs now available to Pennsylvania consumers to-go, not only from the Pennsylvania State store system, but also from retailers with RTDC permits. However, these opportunities bring increased oversight and reporting responsibilities.
PLCB Reporting Requirements
On Sept. 2, 2025, the PLCB issued guidance reminding all Licensed Pennsylvania Manufacturers (LPMs) that quarterly reports must be filed no later than Dec. 31, 2025. LPMs include all limited distilleries, as well as any distillery originally licensed as a limited distillery before July 1, 2024. The reports are limited to sales of Ready-to-Drink Cocktails to RTDC permit holders.
Quarterly reports must provide detailed information, including:
- The quantity of RTDC sold to each permittee
- The purchase price charged
- The product name or brand
Don’t forget, even LPMs that don’t produce RTDCs must file quarterly reports under the RTDCA, showing that no RTDCs were made.
RTDC permit holders have it a little easier. They just need to report the amount of their purchases of ready-to-drink cocktails they resold to-go, as that is used to calculate their renewal fee for the permit.
What This Means for You
If you are a Pennsylvania manufacturer, the message is simple: do not delay. Confirm whether your business is classified as an LPM and file your quarterly reports by Dec. 31, 2025, to be eligible to renew for 2026.
Here at Norris McLaughlin, P.A. we are advising all our LPM clients to make sure all quarterly reports going back to Q3 2024 are filed before Dec. 31, 2025, whenever feasible. For example, an LPM that opened and started producing liquor in Q1 2025, but expanded its product line to include RTDs in Q2 2025, should have filed quarterly reports from Q1 2025 (showing zero production) through now.
Conclusion
While the Ready-to-Drink Cocktail Act has opened new opportunities for Pennsylvania’s alcoholic beverage industry, it has also introduced a greater compliance burden. The holidays are not the time to face unnecessary licensing headaches. By filing accurate and timely quarterly reports now, before you renew, you can protect your license, safeguard your business, and step into the new year with confidence.
For information about national and state liquor law matters or general manufacturing and distribution advice, please contact our Liquor Law, Licensing, Manufacturing, and Distribution Practice Group: Liquor Law Department Chair Theodore J. Zeller III, Esquire; David C. Berger, Esquire, for Pennsylvania and New Jersey retail and manufacturing licensing; Anthony M. Brichta, Esquire, for federal manufacturing, distribution, formula, and labeling issues; Peter G. Manakos, Esquire, for general state and federal licensing questions including TTB filings; or contact our office at (610) 391-1800.