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November 1, 2025 · 4 min read · Michael Stroener

TTB 5130.9: Stop Reconstructing Last 6 Months

Hey guys, today I wanted to talk about TTB reporting, particularly the most effective way to do it. Happy Tuesday, and as always, thanks for stopping by.

I've sat with breweries the night before a TTB filing, reconstructing six months of production from paper logs and spreadsheets. It doesn't have to be that way. Here's how to fix it.

For most breweries, the Brewer's Report of Operations (Form 5130.9) is a recurring bottleneck. The difficulty is rarely the math—it's reconciling disparate data sources (brew logs, cellar notes, POS exports) at the end of the period. The fix is to make reporting a byproduct of daily production rather than a separate, end-of-month task.

The Problem: Snapshot vs. Transactional Data



Many small to mid-sized breweries rely on "snapshot" inventory. You count what is in the cooler on the 30th and work backward to guess what happened during the month. This approach makes it nearly impossible to accurately track the four pillars the TTB looks for:

1. Production: Real-time volume into the fermenter.
2. Removals: Tax-paid depletions vs. tax-free transfers.
3. Losses: Operational shrinkage (spills, bottoms, blow-off).
4. On-Hand Inventory: Ending stocks that match your ledger.

If these don't balance, you're forced to "plug" the numbers, which creates a paper trail that won't hold up under a standard TTB audit.

Implementing Event-Based Tracking



The most effective way to automate the 5130.9 is to adopt a ledger-based system where every physical movement of liquid is recorded as an event.

1. Log Production at Knockout


Instead of waiting until packaging to record volume, production should be logged at the moment of knockout. This establishes the "produced" volume for Section A of the report and sets the baseline for yield tracking.

2. Standardize Non-Revenue Depletions


The TTB allows for operational losses, but they must be documented. Many breweries fail to log:
Lab Samples: Pints pulled for sensory or gravity checks.
Racking Losses: The trub left in the FV.
System Blow-outs: Line cleaning or accidental spills.

By creating a "Loss Log" or using a digital system that requires a "reason code" for inventory adjustments, you satisfy the requirement for Line 30 (Losses and Wastage) without having to guess at the end of the quarter.

3. Centralizing the Paper Trail


Automation fails when data is siloed. If the head brewer has the production logs and the taproom manager has the sales data, the person filing the TTB report has to play mediator. A single source of truth—where production, packaging, and inventory moves live in one place—ensures that the "On Hand" number on Line 33 is actually supported by your operational history.

Audit Readiness



The TTB's 2025/2026 performance plans indicate a continued focus on revenue collection and tax enforcement. Maintaining "audit-ready" logs isn't just about the 5130.9; it's about having a defensible ledger that shows where every drop of tax-determined beer went. If you can't explain your shrinkage, the TTB generally assumes it was sold tax-unpaid.

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How BrewLedger Handles Compliance



We built BrewLedger to be a digital ledger, not just a list of numbers. Every time you log a batch or adjust a keg count, it creates an immutable entry.

Automatic Summaries: Our system tracks production and depletions in real-time, effectively "pre-filling" the data required for Form 5130.9.
* Variance Visibility: Because we use an event-based model, you can see exactly when and why inventory didn't match, making it easy to correct errors before you file.

BrewLedger is built as a digital ledger: every batch and adjustment creates an immutable entry, so the data required for Form 5130.9 is already there when you need it.

View BrewLedger's Compliance Features