Video: DtC Shipping Compliance Deep Dive: Age Verification and Volume Limits | Duration: 4092s | Summary: DtC Shipping Compliance Deep Dive: Age Verification and Volume Limits | Chapters: Welcome and Introduction (3.84s), Age Verification Compliance (236.66s), Preventing Minor Sales (520.465s), Age Verification Requirements (852.04s), ID Verification Methods (1181.805s), ID Verification Best Practices (1469.04s), Volume Limits (1753.06s), Customer Volume Limits (2170.285s), Customer Limit Rules (2404.46s), Tracking and Blocking (2586.835s), Dry-Wet Regions (2884.54s), Alaska Dry Counties (3073.83s), Arkansas Moist Counties (3209.255s), Kentucky Alcohol Laws (3321.205s), Q&A Session (3447.19s), Q&A Session (3469.98s), Updates and Q&A (3528.49s), Age Verification Requirements (3580.07s), Pickup Location Reporting (3656.475s), Shipping Limits Q&A (3799.565s), Arkansas Shipping Rules (3893.09s), Closing Remarks (4019.365s)
Transcript for "DtC Shipping Compliance Deep Dive: Age Verification and Volume Limits": Hello, everyone. Thank you, and welcome to another webinar presented by Solos Ship Compliance. I am your host once again, Alex Corral, regulatory general counsel with Solos Ship Compliance. And I am here on my own today, as you can see, here to talk to you all about a deep dive into DTC compliance. We're gonna be doing a a look into details on, a few DTC compliance rules, that that seem to catch people up a lot. I think if you are a regular, attendee of these webinars, you probably attended our webinar back in July where I presented on a more broader spectrum of DTC compliance issues, what are the states concerned about, what are they how are they enforcing these rules, investigating these rules, that sort of thing. And at that webinar, we naturally got a lot of questions. A lot of them focused on a few specific DTC compliance concerns. And and we thought that it would make a lot of sense to reach out back to you all and kind of talk about these in more depth. You know, it's very hard to get into a lot of details in an hour long webinar where we're trying to talk about 10 different things. So let's scale it back a little bit. Let's just talk about these three big issues that have been coming up with you all and try to get into them a little bit more details, provide all the context and the the additional information, how you can really understand what these rules are, and importantly, how can you manage them to stay compliant. So that's what the the intent of today's webinar is. We'll be talking about age checks, each verification systems, and ensuring preventing sales to minors, volume limits, the different types of restrictions and caps that states impose on how much you as a licensee can ship into their state. And we'll be in ancient to dry regions as well, wet dry borders, which wasn't necessarily a big issue last time. But we have heard a lot of questions come up in the meantime, and it's it's always a good idea. And there have been a couple new states in the last few years that have made things a little bit complicated for managing wet dry regions. So these are the big things we're gonna be talking about today, going forward. Before we get into it all, of course, there is a little bit of housekeeping to do. We are recording this webinar, and we will make it available to you all to, rewatch at your leisure. We'll send a follow-up web email in a couple business days when this webinar is available for you to stream. You can share it with all your friends, family, colleagues, anybody who actually would wanna be interested in these sort of things. You may if this is your first time in the last couple of months looking at, attending one of our webinars, you maybe noticed this is a different system. There are a lot of different, tools around here. One thing we wanna point out is to the side of your screen, there should be a docs, button. That is where you can find one, a download of the slides we have today. So you can download them and and review them at your leisure as well. And we have a lot of maps in today's session, so this might be something you wanna follow along on your your own. You could also find, more information about me and ShipCompliant and a FAQ. In case anything does go wrong with your feed, they have guides on how you can get back into the feed, hear me if you have any audio issues, anything like that. You'll also notice there are two different boxes over there. There's a chat box and a q and a box. The chat box is where we encourage you all to talk to each other, to engage with each other, say how you're managing these things. The q and a box is where you can actually ask me questions, and I will be tracking that and responding to that. If you say, slow down, can you repeat that, that sort of thing, or you have a more complex question you wanna deal with, let me know, and that's how I'll respond to it. So just two different areas there, and just asking you to focus on the q and a if you wanna get my attention and chat if you wanna talk to each other. That all said, again, I think this is a should be an interesting webinar. It's a little bit wonky. I'll I'll warn you right now, but I think it's it's vital information, and we're trying to explain it in a way that I think, you know, can be accessible and and can make things better for everybody going forward. So let's get into it. The first section we'll be talking about is, again, age verification, managing age checks, age compliance, what is going on here. And first off, why is this an issue? Why do we need to be worried about age checks? Well, it really shouldn't need to be said, but it always bears repeat repeating, excuse me, that it is illegal within The United States to ever sell alcohol to a person who is under the age of 21. That is the law in every single state, and it is a pretty much universal law. There are vanishingly few exceptions. I think, like, maybe, and maybe these are in mostly rumors, but I think that in Wisconsin, a 18 year old can have their parents buy them a beer on premise to be drunk right then, maybe only one. Something like that. Those are the only very, very limited exceptions. And it is known that they do not apply to direct to consumer shippers in any capacity. You know, the rules around selling people 21 have been national since the late eighties. This is was a national campaign to make that available at every state. And and so it's really you know, this has been the rules for for four or forty years, for nearly forty years. And so there's really no excuse for not knowing that this is the rule. And like I said, that means that we shouldn't have to say it, but we do always wanna repeat this and make sure that it is hammered in, that it is always and in every situation illegal to sell, provide, sell or provide alcohol to minors. And so this is something that you want to avoid at all costs in all situations. And know that even accidental sales and deliveries can be prosecutable. You know, if if you are are not scrutinizing fake IDs enough, that can be a reason that any state would have an issue with you and might have enforcement actions. And, again, this applies in your tasting rooms. It applies in bars. It applies in liquor stores, applies in stadiums, and it certainly applies for online sales. So, again, just been harping on us for a little bit just to reiterate that it's this is the the the background, that we are managing here is that it is always impermissible to sell to anyone 21, and therefore, it is always necessary to take steps to prevent that. And it's there is a big reason with this with related to, state compliance as well is that states take this very seriously. This is one of the main rules that they bring up to say why direct consumer shipping shouldn't happen because we can't manage sales to minors. I think that is false. I think that's demonstrably false, but it is something that states bring up. This is a big, moral concern. You know, we do not want to, ruin the youth. We do not want to sell either of their growing up. And so, again, if they say that that that sales are happening to minors, this is something that can bring a lot of hay with it and bring a lot of, of interest with it. And, again, if states are finding you're doing this, this is something they will take very seriously. And and this is something that states claim is happening a lot with direct to consumer shipping. Over the last ten years, five years, there have been a few studies that states have published. Big ones are Oregon, Michigan, Massachusetts, and Vermont, separately commissioned studies where they basically get stings, where they they purchased from online sellers, and found that there was wide noncompliance when it came to age verifications and even point of delivery age verifications, you know, products just being dropped off at that doors, products being left with minors. I have a lot of questions about these studies when you actually look at them. It seems like they were really, very small sample groups. You know? In some cases, basically, they did 10 orders and said that six of them were wrong. They they purposely went after people who are nonlicensees and or should not be shipping into those states anyway and so are disinclined towards compliance in other, other, factors. They confused direct to consumer shippers with local deliveries, so they were saying can't allow direct to consumer shipping because DoorDash had issues. Again, these are our issues with those specific studies. Nevertheless, states really believe that this is very common, and they believe that you are actively almost reaching out to minors to sell to them. And so this is just to really stress that it is a very important rule and a a universal thing, again, that we need to do everything we can to block sales to minors and ensure that that doesn't happen, not only because it is law, not only because it is good policy and good humane practice, but because states are really actively cracking down on this. They are conducting stings. They are checking on this. And if they're finding you're doing this, they're not only gonna go after your license, they might go after the entire industry. So this is just to harp on this a little bit and and make sure that it's really stressed in. So what are the steps that we can do to prevent sales to minors? Well, there are a few very minimum steps that you should be taking in any situation, should already be taking. Again, probably shouldn't even need to be mentioned, but, nevertheless, always bears repeating. You should do what you can to, again, block sales at the point of sale and at the point of delivery, from getting wine or any alcohol into miner's hands. Again, it is illegal to sell to a minor even if a minor is buying for their adult. You know? A a 18 year old can't buy a bottle of whiskey for their dad, for their dad's birthday. It's legal. They they can maybe give money to the dad and buy it themselves, but they cannot purchase for somebody else. They cannot receive it even if somebody else purchased it. You always just need to make sure that minors are not even around this. So one of the things to do is have an age gate on your website. It's a little thing. You know, I think we probably all already have them, but just a warning to say, this is a adult site. We are dealing with adult products. You need to be over the age of 21. You can ask them to enter in their date of birth at that time or just have a a notice that they are affirming they are over the age of 21. Some kind of warnings, other warnings on your website that these purchases are only for adults, etcetera, etcetera. You should require purchasers to enter in their date of birth at the time of purchase. I I recognize this is one of those speed bumps that often interrupts a sale and maybe make some people not wanna go through with it. My position, being very conservative when it comes to complying with direct to consumer laws, is if somebody is unwilling to enter their date of birth at the time of purchase, maybe they're not somebody you want to sell wine to to begin with. Again, everybody in this country recognizes that the eight that there is a minimum age and that you're just asking them to confirm at that age. You're not necessarily crying into their their privacy. It shouldn't take too long to enter that. This is just a good faith effort on everybody's part, recognizing that we need to know who you are and that you at least say you are over the age of 21. Again, these sort of age gates are extremely easy to get around. You know, you it's not hard to lie on the Internet. I will admit that. Nevertheless, these are really demonstrations of good faith efforts. You are showing to the world that you recognize you're dealing with restricted products. You're recognizing that there are rules you need to abide with to prevent sales to minors. So even if people do get around it, you're saying you're putting up roadblocks that are saying you do care about this, and and states will measure that. There are, again, also rules around having age gates when it comes to, advertising to minors. So these are just things that you really need to have in your website at a bare minimum, regardless of, you know, when you are putting any information about wine on the Internet. The other way you really need to do, and again, a very minimum basic necessary steps is to work with a carrier who will take steps to prevent, at the delivery, alcohol getting to the hands of minors. There are a few basic things that carriers are themselves required to do. In most states, carriers are required to be licensed by the states. Just as you're licensed to have a direct consumer license, they are licensed to have a carrier license, a transportation license, and those license come with enforcement possibilities. We are dealing with multibillion dollar companies. They do not want to get hassled for, noncompliance with alcohol rules, and and so they are doing everything they can to comply with them and to ensure that the rest of their business is not being affected by what what is a important but honestly kind of minor part of of the overall FedEx, UPS, business model. You know, why it is important, but it's not a major, per product. And so this is just to say that, again, carriers are themselves subject to enforcement action. They have rules. They have things they need to comply with. Again, licensing, carriers must check the IDs at the time of delivery. They must get signatures at the time of delivery. They cannot leave packages of alcohol on stuffs. They they must leave it with a person who can show they're over the age of 21. And and so this is to say that, you know, you have to be working with a carrier that are doing these steps. If you are not, then that is going to, you know, have implications on you and probably means that your your wine is being delivered in a improper manner, and the carrier will be probably be shut down, and you will be, have have strict questions for the state wondering why you're working with a bad faith carrier. You also should recognize that the carriers, you know, FedEx, UPS primarily have taken a lot of efforts over the last ten years because they are subject to all these enforcement actions. They've taken a lot of efforts to shore up their, enforcement, their their their their checks themselves. So, hiring more people, refrigerated trucks. They are having the ID scanners, all that. Those are expensive procedures, and they are passing those expenses onto you with your special wine, contracts with them. And so you wanna make sure that they are actually abiding by those rules and are following up with that because if you're they're not, then one, you could get in trouble for that. And two, then you are paying for a service that you're just not being being worked on. So, again, you wanna be working with the carriers. You wanna be making sure they are doing everything they can, that they are required to do, to ensure that they are not delivering to minors, that they are preventing minors from ever getting their hands on the wine that you are shipping around the country. Again, these are the very basic minimum steps that everybody needs to be taking in every situation. And and so what are the other things that need that are out there? You know, we talk a lot about age checks, age verifications. It hasn't come up yet. Why is that an an issue we talk about? Well, that's because there are, these eight states, seven states, excuse me. I'm trying to quick count my head. Seven states that have actually within their direct consumer shipping law, explicit requirements saying that age verifications need to be done. Now, again, this is not to say that age verifications don't need to be done in every other states. It's just said that that this is a a explicit requirement in these states that you do do these specific processes. You can kinda think of it as as relating to in in your state, there's probably a rule that says, you have to check the IDs of everybody who looks like they're 40. Now it's not illegal to sell to somebody under four who is 40 years old and looks like they're 15. They're over the age of 21. They can buy alcohol. However, there is this extra procedural step that states imposed saying, well, they look like they're 40. Therefore, you're not taking the full steps you need to do, to to verify their IDs. Even if you know who they are, you know that they're over the age of 21, they look like they're 40, their law has a separate procedural step that is required. It's a similar thing in in these states where, again, it is illegal everywhere to sell to minors, to provide alcohol to minors, even accidentally. And so age verifications are always a good idea. In these seven states, it is just an extra explicit step that needs to be taken. And even if you have never sold to anybody 21, even had any issues with that, you know, you you're only selling to to retirement homes, something like that. If a state if Arizona if Michigan conducts an audit and finds that you have never conducted an age verification process, that is alone a a violation of your license in these states. Whereas if you're doing that in California, you know, you know who your customers are. You're not selling to anybody 21 21, but you're not taking these explicit steps. California is not going to have an enforcement action against you because you didn't take these explicit steps. You know, you need to be doing other things to prevent sales to minors in California, but these are not the explicit requirements that are out there. This is, again, in these seven step in these seven states, it's just a condition of your license. You need to take an extra step when you're making a sale. Now what do these extra steps look like? What do these laws look like? Here are a couple examples. As ever, all these rules are written differently in every state. They all use slightly different language. It's a lot of just syntactical stuff. You know, you use the verb first or you use the subject first, that sort of thing. So you do need to understand the differences between what specifically Alaska might be looking for versus Arizona, but you can trust that they are going to have a lot of the similar language. It's going to rhyme with these different codes in Michigan or Kansas. And so these are just good examples of what they what is out there. And Michigan and Kansas are, again, some of the the bigger states, more active states in monitoring this, bringing them up specifically. But you can see there are a lot of similarities. There is a requirement on the licensee. You know, is the direct shipper must or before accepting an order, the holder of a special order license must. You check then the person placing the order. Both these statutes have the individual placing the order highlighted. You shall verify the age of such person either by, retaining a copy of the a photo identification, or physically examining the government issued ID or by using a available Internet based service. And in some states, like you can see in in, Kansas, it says approved by the director. And and in Michigan, it doesn't have any sort of approved by the director, but Michigan still has issued a, a list of the the providers they like. So it's basically setting up that again, this is a requirement on the licensee, on you as a shipper. You need to be checking the IDs, verifying the IDs of the purchaser of the products using one of these services, either physically getting their ID and checking it or using one of these online verification services. We have a quick question in here. I'll just quick jump back here is that map of the explicit age verification states, e seven. Just a reminder, in that docs tab, you can actually download the the quest the the slides for today too. So all of the maps that you are gonna see today, you can download and keep them on on your your slide. Of course, we do maintain these, within ship and point as well if you want more information. But now to move ahead. So, again, looking at these laws, licensee must verify the age of the purchaser, physical ID, online verification service. What does it mean in in practice? Well, again, it's all about just checking the purchaser's ID. And, again, in these seven states, it is a specific process that must be followed. If you were failing to comply with that process, that is itself a violation of your license. Whereas in every other all the states, again, it is still legal to sell to minors. In those other states, you don't necessarily need to demonstrate the specific process if you're under audit. If you're not doing any type of a, HJETs, I think that a state might still have an issue with that. But, again, these seven states just have an explicit process. What does this process look like? Again, it's getting a physical copy of the purchaser's ID. If they are at your tasting room, if they're buying it on premise, it's pretty easy to do that. You should be doing that. Just take a look at the ID, examine it. You might want to copy the information, retain that for future purchases. Similarly, if you are buying online, if you're working with club members or if you have a good relationship with your consumers, you can try to, get a copy remotely. They can send a photograph of their ID. They can send a fax of their ID if you or do faxes. If they're comfortable, they could send an email perhaps. Again, you could then keep that information. Once you have examined once, you can say this is a trusted consumer. We have verified the IDs. We can allow purchases going forward. The big thing you wanna be worried about when it comes to, physical IDs is that there are huge privacy concerns with this. You are collecting, you know, vital private information about a consume about a consumer. And while you need to know their name, address, and date of birth, you know, there's other information on the IDs, especially if you perhaps got their passport, instead of a driver's license that they may not want shared out there. And especially if you're operating in California, which has or selling to California consumers, which has actual privacy laws, data privacy laws on the books, you really wanna be concerned about how you're retaining that, how you're keeping it safe. You know, I'm bet you there's a lot of people out there who are not very comfortable about sending a copy of their, their ID through email. So you just wanna be careful about that. If that's a possibility, it's a way you can check IDs. You just wanna be careful about how you actually set that up and manage that. The other solution is to use one of these Internet based services out there, and there are a variety out there, that offer age verification services. Age verifications are actually a probably a small part of their overall business. These are, again, very large companies with big, broad offerings out there. They are doing a, you know, person verifications overall. They're working with a lot of banks, with governments, with different, privacy, customer concern issues where you need to verify this person is actually who they say they are. Again, age verifications are a small part of the business, but they are a big or are a very, welcome one. They are a very, robust service that they do provide. So this is just to say that, you know, there are a lot of services out there, and they do a lot of different things. But these is this is really the the the gold standard when it comes to these online, verification services that are mentioned in the statutes because you wanna find one of these services out there. They work by using by by pulling in available public records. So they are are, collecting and searching through voter rolls, like, in tax databases, property records, old fashioned white pages, basically anything they can use to to determine who everybody in the world is. You know, they they they collect a lot of, ID services as well. So they just have all of the basic biometric data for, you know, frankly, most people in the, in the at least in The US out there so you can verify, you know, again, who you are and when a consumer says, I am this person at this address and I am of this age. This service will look through their available public data and and recognize that, yes, this person is there is a person at this of his name at this address who is over the age of 21. Again, these are not flawless services. There are issues that come up. We found that these these issues are pretty vanishingly rare. They're really not very common at all. These services are very good at doing what they do. Again, you know, they're working with, more powerful people, let's say, than the wine industry. So, that they have a lot of interest in making sure their services are good. They really do work very well. We do find some false positives and negatives. We find more false positives, than, you know, false negatives. That is situations where they say the person is not over the age of 21 rather than where they they say that somebody under the age of 21 is over the age of 21. In fact, I'm not even really sure of cases where they have gotten it wrong the other way. So, again, this is just to say they are good services. And even if they get it wrong, you are then at least complying with the requirements of these states to use these services. You're demonstrating good faith. You're doing everything you can and that you're probably required to to verify the ages. If you wanna find out more about these services, I think you frankly, they they're big, and they have a lot of PR services as well. We can direct you to them if you wanna find more information, but probably be best hearing from them directly if you are concerned with with what they're doing. Just quick moving on. Again, when should you be doing these services? When should you be checking purchasers' ideas ideas? Excuse me. And the answer is you you should always be doing it. It is always a good idea. Even in the states where it is not explicitly required, it is always a best practice to be checking IDs, to be verifying IDs, to be verifying ages, to be knowing who your consumers are. We highlight those states earlier because, again, it is in their statutes. There is an explicit requirement that it is part of your your your license to take those specific steps. Failure to take those steps is then a breach of your license as opposed to just not checking IDs. And and, really, you wanna do it in those states so you have that paper trail. When the state says, are you checking IDs? You can say, yes. Of course we are. And and then you can move on to the rest of your life. But, again, it is always a good idea to know your customers in in every state because it is always illegal. It is always prohibited to sell or ship to a miner. There is no exception to that in the entire United States. And so this is something that you really want to take to heart and always use as best practice to do what you can to check your IDs, to know your consumers. Of course, there's all those minimum steps, the the age gates, the can we trust you? Do you say you're 21? That is good steps as well. Those are necessary, but it is good to take that extra step and say, well, we wanna verify. We can trust you that you say you're 21. We're gonna verify, though. We're gonna make sure that that we're doing everything we can because if nothing else, that is that, demonstration of goodwill. You're doing what you can to prevent, errors. And there are frankly a few states that are not highlighted on that map that think they have a explicit requirement. Massachusetts, I'm just gonna highlight. They are very much on the warpath around direct consumer shipping. The director there is not a fan and has done a lot over the years to find problems with it and to, find reasons to shut down shippers. They have conducted a lot of stings. They do think that it is a requirement that you you cannot sell to anyone but I think anybody 21. So they think that you really need to be checking IDs there. So Massachusetts might be a state that, again, it's not in their statutes, but it would be a state I would recommend just doing age checks there all the time anyway because, the the ABC wants to check wants to get you in a trap there. Certainly other states, you know, big states, Texas, Florida, you just wanna be careful about this. This is what it's all about, is demonstrating goodwill and and and tracking your orders so you don't get in trouble if you can avoid it. There is, of course, on the question of gift purchases. You know, when we look at those those, statutes earlier, they explicitly only mention checking the purchaser's ID. But if you have somebody who's buying you know, you you sell to a law firm and they're buying a couple bottles of wine for their 50 best clients. What do you do about those clients? They're shipping to a round of other people. So, again, there's no explicit requirement out there to check the recipients of the the the shipments. You know, does not say in any statutes you need to be checking the IDs of all 50 people buying that they're being purchased for. And in some situations like that, it it could be really impossible. I get it. You know, you're not going to then tell that law firm you need to get IDs from the 50 people. You know? That that's ruining the gift. If nothing else, it can be very difficult to manage that. And so this is kind of why it lives exists a little bit in the. If you are able to do that, if you are able to check the the IDs, age verified, the people who are being, sent wine, that is probably a good idea. Again, recommended, certainly good practice to take if you can do it. But, again, we recognize that's not always available. We recognize that it's not an explicit law. So, you know, you will certainly get in trouble if your law firm buys for somebody who's under the age of 21, but you need to be a little bit, you know, it's just kind of difficult to manage that necessarily in the situation. And so, really, what it comes down to then is really relying on your carriers. They're that last element of defense to make sure that even if wine is being watched, somebody's under 21, that person will not be allowed to keep it. They'll not be able to keep that package and retain it. It will go back to you as the shipper, and that sale is not consummated. So, again, it's a little bit of a tricky area. If you can do it, it's a good idea to check gift purchases, but we really need to rely on their carriers to manage that as well. Alright. So I hope that that that, addresses a lot of questions we had about age verifications. Certainly, if you have more, send them in. I'm gonna take a quick break here just to grab some water so I don't cough on stream, and we'll move on to to volume limits. Thank you for giving me my pleasure. Moving on. So the other issue we talked a lot about at that webinar back in July that we had a lot of decent questions about, a lot of good questions on, what does this mean? What's the practice? What are the details here? Or volume limits? So let's move on to to what these are. What are volume limits? Again, it's pretty simple. These are just limits. These are caps that a state will impose on you as a shipper, limiting the amount you can ship in at a given time. These come in a lot of different varieties. There are different rules. There are a lot of details, and this is an area where you really, excuse me, need to be tracking the specific rules of the different states very directly and not relying on, what happens in other states, what happens in your home states. Each state is different. There are a lot of similarities out there, but each state needs to be treated differently, needs to be tracked separately, and and they have their own nuances. So these are there's a wide variety of of these volume limits that are out there. Why do states impose volume limits? Well, there there are a few main reasons. A big one is to prevent secret distributions. Again, states that states are concerned about direct consumer shipping often think that you are doing this so you avoid your distributors, that you're actually shipping, you know, tens of thousands of cases to consumers because you want to avoid the three tier system. That's not happening. Again, I don't think anybody who's realistically looked at this industry thinks that's an issue. Nevertheless, states are concerned about this, and so they want to prevent secret distributions. Again, just a reminder, direct consumer shipping, all the rules of the states say that these need to be end sales to consumers, not for resale. So there are already rules preventing you from particularly doing distributions, but, nevertheless, states then say, we want you to, you know, avoid that by, you know, putting a cap on how much you can ship into the state or how much you can ship to a given person. Again, when it comes to those those, rules, there are also rules against or or or values around overconsumption. Don't ship too much to a person. So, you know, again, a a rule going back to prohibition is, declining pro, consumption, not encouraging people to drink too much. There are also, again, interests in encouraging local consumption, local purchasing. They don't want people just buying, wine from out of state. They want them going to local retail stores. They want them, engaging in the full feature system. So these are, again, just kind of ways to limit how much you can be involved as a direct consumer shipper and encourage consumers to go for other other areas. Who are these limits imposed on? This is a question we get asked every now and again. You know, these are who do we need the tracking here? These rules are always based on the individual licensees. So what one licensee can ship into a state, at a given time, It is impossible to track rules on how much a given customer can receive total. You know, if it was state if Texas said a given customer can only receive 1,000 cases or, you know, 10 cases entirely in a year, from any winery. That's impossible to track. There's no way to manage that. Similarly, you know, if a state said we will allow only a 100,000 cases from all wineries in a year, no way to track that. So these rules are imposed on the individual licensee, what you can ship into that state in a given time, to whom. And states are tracking this. They they are really reviewing their shipping reports. They require you to indicate who you're shipping to, when, and and they're using spreadsheets. They're using online Excel forms that are much easier to sort, much easier to search, and much easier to find, scenarios where where it seems like something has happened. And so, again, states are aware of this. They're cracking down on this, and an area we just really want to highlight, what this looks like. So what do the different volume limits look like? Here is our first of a series of maps. These are states that have some kind of a volume limit. We've broken them out here based on total state aggregate limits and state customer aggregate volume limits. You can see there are a only a few states that actually have a total state limit. Texas, Indiana, and Michigan, those are states that block how much you as a individual licensee can ship total into the state in a given year. In Michigan, that is at one 1,500 cases total. Indiana, it's 5,000 cases total. Texas is 35,000 gallons total. As ever, throughout this this presentation, when we talk about cases, that is a standard 12 or 12 bottles of, 750 milliliters each, so nine liters in total. That's what we mean by case. You can see that that Texas and Indiana also have a customer volume limit you may be tracking as well, whereas Michigan, it's just a total state limit. You can if you have one customer in Michigan that really likes your wine and wants to buy 1,500 cases, in theory, you could ship that to one get a customer. But, otherwise, it's, you know, a total for the state. You could see there are a few states highlighted here with the star, Nevada, Wyoming, and New Hampshire. These are states they do not have a specific, like, a cap on how much you can ship to them. Instead, they have what's kind of a distribution offer limit, which says once you ship a certain volume into the state, then you need to offer it to a distributor. In in in Nevada, it's specifically really, you just need to fill out in another form. You need to find a Nevada licensed distributor who, in theory, you might sell to. You need to appoint somebody, but you don't actually need to sell to anybody. You don't need to sell to a Nevada distributor if you hit that limit. It's just basically another form you need to fill out as opposed to shipping on your own if you're a very small, volume shipper in Nevada. In Wyoming and New Hampshire, it's a little bit different because those states are control states, meaning they actually are the distributor of wine in those states. They require when you hit a certain volume limit limit per brand or per product that you then need to offer those. You need to go through the listing process to the state. I'm not sure if I've ever heard of anybody actually getting in trouble for not doing that in in, frankly, any of these states. Nevertheless, those rules are in place. And so you maybe wanna be tracking, you know, your total volume in Nevada to know when you need to fill out that extra form or when you need to, appoint a distributor as theoretically who you would work with in in Nevada, or if you need to then consider going through the listing process in Wyoming or New Hampshire. Again, you just need to offer your products to those states. There's no guarantee they're actually gonna pick them up or anything like that. And, again, I'm not sure how strictly those enforced, but, again, all direct consumer shipping laws are important and and can get you in trouble if the state, finds you or not complying with them. So these are are the broad, breakdown of total, kind of state limits that are out there. We're now gonna break down what these customer volume limits look like. What is happening in all of those green states, basically everywhere. Well, I put Michigan that's highlighted here. So what does it look like? Here, we're we're looking down at the breakdown of customer volume limits by customer type. So all of the the, the states there are per person limits, whereas the per person, per individual limits, whereas the teal states are per household. And then there is Kansas, which says they have a both limit. Talk about that a little bit more, but, again, wanna take a moment on this, look down at that. Again, most states are are addressing this as a per person limit, how much a individual can get at a at a given time. But there are these states that have per household where you need to be accounting for for what the household is purchasing. And here we are looking at the last of our maps. You kind of are when you're looking at this on your own, you're kind of going to need to bounce between these different maps to say, is this per person or per per, individual? And then this map will break down two things here. One is the, term, the the time limit in and that's involved. This is the color coding coordinating on here where so there are states that have a per month limit. There is, Connecticut that has a two months limit. There is Arkansas that has a per quarter limit, and then there are all the other states that have a per year limit. I think with the per year, I think Nevada is the one that is a fiscal year. Wyoming might also be a fiscal year too. But, otherwise, it's it's generally the calendar year when you need to be tracking that. Again, these are things we have set up within ship compliance. So if you're a user, you can find more details on how it is broken down in your state details. But then on the state of this page, we also indicate the, volume that is allowed in the given different time. So you can see in the the per year states, most of these are around 12 cases per year. You have a couple that are 36 cases per year, 24 cases per year. Similarly, a lot of the per month states are two cases or one cases. You got, Texas, which gotta be weird is in nine gallons, which is the case. It's how we we track that, but they say gallons, so we make it a little bit more nuanced. There are a a couple of states that have had an asterisk here, Alaska, Texas, and Tennessee. Those are states that actually have both a per year and a per, month, requirement. Alaska is actually not a per month. It's a per shipment requirement. You can see them down here in the the lower right corner. Alaska, it is 12 cases per year, but also 18 liters per shipment. So, you know, you can't sell send 12 cases all at once to an Alaska resident. You can only sell 18 liters at a time. Similarly, in Texas and, Tennessee, you can see they have a one case per month limit. They also have then a per year limit. So in in Tennessee, you can only send them three cases in different months. Similarly, in Texas, it's, I guess, equivalent of four cases in different months as well. So, again, these are all just very individual. You when you're shipping into the individual states, you wanna recognize what how they are treating each of those different orders, tracking these different separately, and and just, you know, recognizing these different, different rules that are out there. And, again, you can download these maps in a doc section so you can review these at your own leisure. You can check-in your state details. We have public pages where we break down these rules as well. So if you have want more questions about any individual state, we are happy to provide more information. But, again, it really comes down to recognizing the different states out there and how they're treating this. Now what do some of these rules mean? Again, how do we break down these rules? Well, there are the different types of aggregate limits. There are the state limits, which apply to all shipments into a state at different time. Again, those distributor appointment rules do not require that you actually sell to the distributor, just that you consider it, that you have somebody in mind that you're you're offering maybe to sell to them. It doesn't mean you need to go through with it. When we're looking at at customer limits, the big thing to break down is individual versus household. Individual does mean one person at a time. It includes sales to any addresses that the individual might have. So if you have a consumer who, has is having wine sent to their business address and to their home address, you need to account for all of those orders at once. But it does mean that individuals within one location can buy their up to their individual limit. So if you have a married couple in a house, they can each get two cases in a month. If they have an adult child living in the house, that adult child can also get two cases in a month. And and so you can kind of build up from there. Difference is household. Household does mean everybody at an address. So that includes couples. That includes any living children, adult children there, perhaps even, roommates, that sort of situation, anybody who is considered to be at an address. This can also include sales to other addresses associated with that household. Household is a very broad term here, that it it kind of means the the entire family unit. So, again, if you're selling to, if you're they're having wine shipped to their business addresses, vacation homes, those are things you need to account for when it includes the entire household. You know, years ago when I first started, there was a a case where I think the County of Kauai called me up directly about a order that was was missed, shipped where, a husband had wine shipped to his wife's school, you know, a completely different address, completely different name, but the county of Kauai happened to know that person directly, the the the the, examiner there, and so was able to say, oh, we recognize this as a violation of our per household rule. And they just knew what was going on. They were viewing their shipments. And and so, again, that's just to say that there that this household rule the states that have a household rule, they do tend to apply it pretty broadly. And talking specifically about Kansas, when you look at their statute, it does say per individual. Kansas has let us know over the years that they interpret that to include the household. So it's a little bit of a special situation. It's if somebody wants to argue with Kansas, maybe they can make it. But Kansas has been enforcing the schools strictly, really cracking down on people, really reviewing their their their, shipping reports very carefully. And so that's just a very special situation where we apply both a household and an individual rule just to check everybody as best as we can. So how do you prevent these capital violations? Once you understand what the rules are, it kind of is simple. It just comes down to tracking consumers and their purchases and then blocking them when they are hitting a a volume limit or when you're shipping to a state, tracking your overall orders to those states and block and saying, sorry. We can't ship more when we hit a limit. So it comes down to recognizing the in the purchaser. Again, this is the the breakdown. Is this an individual state or is this a household state? Depending on that breakdown, who do we need to be tracking? How do you track them with the available data? So you can use their name, the address, the date of birth, and the credit card, very specific information that you can be using. So, again, if you're in a household state and, John Smith buys two cases of wine, and then, you know, Mary Flatley also buys two cases of wine, but she happens to live at the address and she has the same credit card, you can say that's probably a household. I'm sorry. We need to block this order. Conversely, if you have a John Smith who is buying two cases of wine, at one address and then a John Smith who's buying wine at another address, looks like two different people. Many people can be called John Smith, but they have the same date of birth. They have the same credit card. It's probably a consideration. They're the same person, and so you want to be be tracking them. In theory, if you are working with club members, if you have a way to individually identify consumers, that could be a way to track them as well and to you know, we we don't need to be accounting for all these variations in names, variations in addresses. We just know that you're, user 1135, and you have hit your limit already. So that's a possibility out there, probably a little bit more, involved than necessary, because we wanna use the the available address information. This is how we're tracking within ship compliant when we are tracking your consumers and and providing alerts when they're hitting a cattle in it. Is we are, again, looking at names, addresses, date of births, all the sort of of identifying information we can, and we're comparing it. We will have to account for for variations within those as well. So initials, nicknames, vacation houses, all these things that, again, states are aware of and states are cracking down on. When you find there is a potential violation, what you really need to do is communicate. You need to communicate with the consumers. Ideally, before the sales can be consummated, you know, you wanna block the sale before, like, a you purchase Bin Aid. You don't wanna return money. And when you communicate with them, you wanna be very gentle. You wanna be very nice because these are clearly valuable consumers. They are your fans. They are buying as much wine of yours as they can. But so you wanna be nice in your communications, but you need to inform them that there is an issue, that you just need to delay the shipment. You need to identify a new shipping schedule. We'll send it next month. We will send it next year. There might be a free T shirt involved, that sort of thing. Again, you recognize that they are a valuable customer. You wanna treat them well, but they need to recognize as customers as well that you are simply following the state's law, that you are doing everything you can, to, to, you know, abide by the rules. And if you are bound to be violating those rules, then you they can get you in trouble. And if you get in trouble, that means they can't buy any more wine from you at all. So, again, this is just a clear way to talk about these rules and address, issues when they come up. And we do get the question every now and again, yeah. You know, how do I just get around? I you know, I this great customer, I just need to send them three cases this month. Let's just figure it out. And the answer is you don't. You just don't get around cattle just like you don't just get around any of these rules. These do matter. States are tracking them. They are cracking down on them. And if they find that you're not taking them seriously, again, enforcement actions, reasons to take away your license, etcetera. They're annoying. They're problematic. They may not make sense. They are anti ecommerce, but they're still a lot of the land, and you need to abide by them as a licensee. So when a consumer hits a limit, you do need to take it seriously. You don't look for loopholes. You just wait until the next time period, when there is a a, you know, next month, next year when they can ship again. If you have consumers that are repeatedly hitting these limits, again, you really want to contact them and be very nice about it. Say that we love that you are such a a great customer, but if they continue to do this behavior, they're gonna get you shut down, and that means they can't buy from you at all. And they need to understand that they are putting you at risk. Again, you can do this in a very nice way. You can maybe offer them discounts, and club access, tasting room privileges. Be nice to them, but they need to understand that they are risking their ability to buy from you in the future if they continue to take the behavior. If they don't like the law, they can talk to their their congressperson. They can reach out to their state legislator, say change the law, give you a better limit, but you need to abide by the law. And, again, states are actively reviewing these these reports. They're tracking down, and they are strictly enforcing these rules. So you need to take these seriously, when they happen. Now briefly always happens where I think, well, this would be twenty minutes, and then, fifty minutes later, I'm I'm rushing through everything. I'm gonna talk briefly about dry wet regions and how to manage these as direct chippers. Again, dry wet regions, these are basically areas in The United States that have, enabled a local option rule to prohibit the sale of alcohol in some capacity. This was a very big thing coming out of prohibition to encourage local control, to prevent undue foreign influence, you know, all those evil, Budweiser and Miller producers in different states encouraging overconsumptions. We know in this local community, we cannot allow a sale of alcohol. That's what these are about. And there are a lot of varieties in what dry regions can look like. There are certainly places that have complete bans where it is illegal even to bring alcohol into that area. And there are a lot of places where it's you know, you can't sell spirits after nine. That's sort of when it's. A lot of variations in what these can look like. There are a lot of variations in the product types that are affected. You know, a lot of places might ban the sale of wine and spirits, but allow beer. There are a lot of varieties in how these different jurisdictions look like. Counties are often brought up, but, actually, we're really looking mostly at cities, even zones, districts within cities, townships, whatever those are. A lot of different variation out there, and there are always exceptions even within the the dry regions. You know, there's always a a golf club that has been in existence since 1870 that needs to have a a a, clubhouse open. Excuse me. So what does this look like nationally? Here is a it's a Wikipedia map I I took from them. Thank you very much, Wikipedia. I am a a supporter of HuePayMoney. Here's a breakdown of the overall dry, wet, moist county list in The United States. You can see this is pretty widespread. A lot of states that have these rules, different verts, restrictions. Again, the consideration what does moist even mean. Thankfully, for direct to consumer shippers, most states actually do not impose dry wet restrictions on you. They actually explicitly exempt you from dry wet restrictions saying you can ship into areas that otherwise prohibit the sale of alcohol. There are exceptions to that. You know, there are these, seven eight states here. Seven states. Excuse me. I can't count today. Seven states that do have, that do imply their dry wet restrictions on direct to consumer shippers where you need to be aware of. Four of these, I'm gonna do get through very quickly because they're very small. Florida has a a prohibition in in Lafayette and Liberty Counties. Those are the smallest and second smallest counties in Florida, respectively. They're in the Panhandle. A combined population of about 16,000. So respectable, but not a huge concern when it comes to Florida. It's a state of millions and millions of people. There is also New Hampshire, Vermont, and Virginia. In those states respectively, they the the dry locations are Ellsworth Town, Baltimore Township, and Brandonville Township, which all of those have a combined population of about 450 people. So all due respect to those locations, I'm sure they're beautiful and very lovely. Not a huge, drivers for for wine shipping. So we have blocks in those areas, but you don't need to worry about those as much. The states we need to be concerned more about just because they're complicated and and much more active are Alaska, Arkansas, and Kentucky. So a quick breakdown of what these look like. Here is a brief map of of what the Alaska dry counties look like. These are very community based. These are little botanist map. This is available from the AMCO, website. How Alaska manages these? There are, again, local option communities. They are widespread at the state. They in fact, most of the state ends up being dry when you look at the county map. Alaska has a very difficult and long history with alcohol, related issues, especially among the native populations. And so these why these local options are very widespread, very common, and very strictly enforced by the state and local communities. I don't know if anybody has heard. Apparently, there was recently a Supreme Court case where a, a bush pilot flying people to one of these local communities didn't realize that somebody had snuck a six pack of beer on board, and the state was trying to prosecute the pilot and and take away their plane for violating the local option rule. So, again, just to say that the state takes this very seriously. The pilot was was clear. They did not have to give up their plane for something they didn't know was wrong. But still, again, twenty years of litigation. There are a lot of UPS only communities in in Alaska. Again, FedEx and UPS are not able to deliver to most of the state, and so they rely on the postal service for last mile delivery in a lot of regions. However, the USPS is prohibited from accepting packages of alcohol. So those are not necessarily dry wet regions, but those are areas where, again, limiting your ability to ship to those regions just because of a different thing. It can look like a white red white dry distinction. It's separate but similar. One thing you can do in Alaska is ship to a holdout location in one of the big cities. FedEx and UPS are approved to ship into pretty much all the big cities there, Sitka, Juneau, Anchorage, Fairbanks. And I think that hold that shipping is fairly common, especially for small communities. You know, you you ship it to a a hold allocation. People will drive down a month later and pick it up. So I think it's it's fairly common practice up there. However, again, you know, there is that that you can't they may not be even be able to bring it into a local community. So consumers may wanna be aware of that and and be very careful when they are traveling back with wine in the state. Quickly, here is the Arkansas map. This is a a GIS website service that the the air that Arkansas has provided. Broken down, the yellow areas are the dry regions of the state where it is legal to ship alcohol into. The blue regions are the, the clear areas. When we're breaking this down, there is a a very nice distinction between the dry and wet counties. There are about 20 of each, very easy to track. They're either all open or all closed, very simple. It's the other 20 moist counties that are very problematic, and they're problematic because their boundaries are not based on cities or ZIP codes. They're based on what's called a township. Townships are basically voting precincts, which change a lot and are not identifiable on address information at all. Basically, the only way to check this and the way that the state council has even told us to check this is to use this map and a Google map and eyeball it and say, well, it looks like it's in this region or not. A lot of situations, it's actually fairly possible to do that. A lot of situations, it's it's really difficult to do that. So this is within ship compliant. We do have a warning when shipments are going to a moist county. It's a warning. It's not a block, but we're saying we cannot verify the the the validity of the shipment. So we ask you then to, again, look at this map, eyeball it, talk to your consumer, verify. If you can confirm it's good, then go ahead and ship it, but we are not able to verify this on our own, and so this is just an alert. Again, dry counties will have a complete buck on. Don't ship there. And and so the state has a lookup tool where you can look up addresses. It requires downloading that GIS map and being very handy with GIS services. So I don't recommend it, but and it's also not guaranteed by the state. They say it is not, you know, verifiable on its own. There are ways to do it. It's difficult. And, again, you just kinda need to be aware of these moist counties and addressing those issues individually. Last, quickly, hopefully, I'll be talking to Kentucky. Here again is the ABC map breakdown of the I think I took this from Wikipedia as well because ABC has taken down their map. But here's a breakdown of of wet counties, dry counties, moist counties with exceptions, and then dry counties with exceptions. So, you know, there it goes. Always exceptions. Again, this is fairly straightforward in the wet dry counties. I I kind of grimace because it's not actually that easy in Kentucky. Kentucky has a lot of weird exceptions. But dry wet counties are fairly simple enough to say yes, no. And moist counties are even worse than in, Arkansas because there's not even a map. These are even based on even more distinct voting precincts that, again, change all the time. There's no map. There is a lookup tool on the Kentucky ABC site that you can use to look up an address and see if this is good. It has an explicit disclaimer that says not to be verified, cannot be used alone, you know, for essentially entertainment purposes only. It useful, absolutely, but, you know, you can't necessarily rely on it to to clear you all the time. What Kentucky instead has in place to help you with your liability is that they shift the the the liability, onto the consumers. So if you are at least taking affirmative steps to check with your consumers, you know, you have a checkbox on your site that says you live in a community that that allows the sale of alcohol. That is going to clear you of any liability for an improper shipment in Kentucky. If the consumer is themselves saying they can, receive an order, they are liable if that is not the case. And and so, again, if you can still get in trouble if you're not taking sufficient or efforts, if you are willful about this. Kentucky does have a lot of dry areas. Based re re, protect this enforce this rule strictly, just as strictly as Arkansas and Alaska does. So you wanna take efforts, but, again, there is this at least an out in Kentucky. If you are asking your consumers, they can have the responsibility if something goes wrong as opposed to it being on you. Like I said, it's always seems like it's gonna be a short one, and then I end up scrambling at the end. So I hope that this was informative. I hope you got a lot of information. Again, especially in those dry regions, I may have spoken a little bit quickly. So I will stay over time. We are almost at the end of our time, so I understand if you want to wrap up. I'll stay over a little bit and answer some of the questions we have been getting in. If you have more questions, I can stick around. Again, we are recording this, so you can come back and, watch it again later, hear the questions later if you need to jump. Want to thank you again if you do need to leave at this time. But for anybody who can can stick around, let's quickly go through some of these questions here. So let's see. Going back to the example of law firms, you know, sending to all their their different clients, I think so the question is, can you add verbiage asking them to acknowledge that they are over the age of 21? You absolutely can. I think, again, just like with Kentucky saying you are in a region that can accept shipments, that's probably a good idea everywhere. Just have that as a standard boilerplate in your your your, acknowledgments at the time of purchase. You acknowledge that you are over the age of 21. You acknowledge that anybody you are sending wine to, all recipients are over the age of 21. You acknowledge you are in a region that allows the sale of alcohol. All good things to have in an airy case. Are they going to make sure you don't get in trouble if something goes wrong? No. These you know, they're warnings. They're they're they're they're communications. You're the state will say that you should take extra steps, involved. So if they're not guarantees, but they are certainly good ideas. And I think that that is a good idea to have some sort of verbiage. You know? I'm not I'm not the recipient of this. I acknowledge that the recipient is over the age of 21 as a consumer. Quickly sorry here. I kinda forgot, what this page is about that we're looking at. Just to let you know, please scan this QR code where you can follow us on LinkedIn. You can find more webin updates and webinars. We're planning future webinars in the next couple months. All other important emails and other marketing information from from Ship Compliance. So please do do check this. Again, sorry. Quickly scanning through everything. Getting back to the questions. This question relating to Wisconsin requiring tracking reporting the date of birth and providing that in your shipping reports. Yes. That is a requirement in Wisconsin. Wisconsin is not the only state that does ask you to collect date of birth, from the purchaser. I I guess this is asking even also about the person receiving the direct consumer wine shipment. I think Wisconsin does have those those verbiage in place, does requiring that. Again, it's very difficult to do so, and I think that I'm not sure that Wisconsin has ever gotten anybody specifically in trouble for not doing that. But this is to say why it is a good idea to do it if you can. And that goes back to the acknowledge having the the consumer acknowledge that they are sending only one to two people over the age of 21. You know, again, asking the consumer to to get the ages of different recipients if you can, and perhaps then considering if if a state like Wisconsin is not the state to to, enable gift purchases for if that is not something you're going to manage. But, again, this is just to say that it is always a good idea to get date of births from a purchaser at least, everybody else that you can involved with the sale. Again, even in the states that do not have it specifically written out of the statutes, states do believe this is rules. They're enforcing it. So certainly best practice if you can manage that. There we have a question about, specifically about Amazon pickup kiosks and I think other holdout locations as well. How do you manage these for reporting purchases? How do states recognize this? And the answer for that is it's a little bit complicated because you really want to report the sale as going to the consumer's address. You want to indicate that it is the consumer making this purchase, and it is that is where they are, at least in theory, receiving the wine, purchasing everything. That is the household at issue. For one, you don't wanna have too much, confusion when a state's looking a report and saying, why are there, 3,000 cases going to this one location that is actually a, you know, 2,000 cases last year that all went to Whole Foods. That seems weird. So you want to identify it is the consumer's house that is really going there. And so you should probably treat the the holdout locations as a intervening step. You know, the sale is made to a consumer's home, and then we're subsequently going to have a a, like, a, redirect the shipment to a different location after the fact. So if you can report as if going to the the the consumer's home, not a a pickup location, and then kind of adjust that later in the actual delivery process so that it gets redirected for the pickup location. Because, again, states are gonna if they see a lot of shipments going to one location, they're gonna have problems with that. If they see that it is a a business address, they may have questions about that. This kinda relates to other issues where, let's say, you have a doctor's office where, you know, there are five doctors and each of them are wine lovers, and how many wine can you get there? Again, this is a variation in state rules that have perhaps a per address rule where they will acknowledge that it's a business address. You can ship to a lot of other places. So I guess I'm getting a little bit off topic here, getting a little bit of far field from the direct question. But it's it's just to say that you want to be reporting sales going to the end consumer. That is this consumer at this address that is going to be consuming it. This is the address where we expect them to be consuming the purchase as opposed to this is necessarily the address that they're picking up. It's not necessarily the one you wanna be reporting on, when it comes to those shipments. It can be a little bit difficult to manage that. Again, I think it is the the redirect in order after you have entered it in, after you're managing your reports. I have a question here about Arkansas. Again, they're they're strict about their their their, dry right regions. If they find you shipping to a problem residence, they're gonna take away your license. That is, again, one of these really strict rules is do not ship to dry regions. Arkansas does take it very seriously. So if a person is at their individual limit, can you ship, in excess to a family member? Again, yes. If this is a state that has a individual limit, one person can receive so much at a given time, they could have it redirected to their to a different individual in the same house. You know, mister and missus Smith can each receive two cases of wine as individuals in a state that has a two case per individual limit. And and so there are ways you can do that. In theory, even within a household limit, if you have friendly neighbors, you could maybe, you know, have them purchase it for you and and you pick it up. Again, there are ways to make this less apparent to, to to states. But if the state does see something is wrong, if they think that something weird is going on, that is reason for them to enforcement actions. And so I do not want to encourage people to, necessarily, again, just get around it. But if you are having a individual or household that is hitting their limits, if in theory there is a different individual or household that could make that purchase instead, there are ways you could you could consider how that could work out. I'll just put it out that. And it does seem like it was the last question. Again, we are recording this. We will let you know as soon it happens. For Arkansas shipping to a how in a wet region, that's that's a new one to me. I'm not sure how Arkansas feels about how some states don't really like it all that very much because, again, they think it is shipping to a business location. I think we we can look into that and try to get back to you. That probably work. I think that is one thing to consider, especially with with, I I kinda mentioned it earlier, Pulaski County in Arkansas. Pulaski County is where Little Rock is. It's a moist state. It has over, you know, nearly 500,000 people in there, and the moist region is one small little section in the bottom of the county that has maybe a thousand people in there. So it is still illegal to ship to people in that small region of Pulaski County, but, you know, there's a problem with everywhere else. In theory, yeah, you you could I mean, somebody living in that that dry region of Pulaski County, if they work in in, Little Rock, could have wine shipped to their business location in Little Rock and then probably drive it back to them their home in in that that the dry region. If they send it to a wet part of Pulaski County, yeah, I I I I'm, again, I'm not your attorney, so I cannot say specifically how this would work for out for you, and I do not want to say something is fine and you get in trouble for this. I would expect that would be alright, but you might want to reach out to the state and you might want to confirm. Actually, we have somebody coming in. They check the state or they said, ship to a Walgreens for pickup, and they said no. Yeah. Like I said, Arkansas is a strict state. They really believe in this, and and they say actually, that's a great point, Kelly. Thank you very much. You that is the rule in in in Arkansas is you cannot ship to business locations. So I'm sorry. I was lying earlier when I said that somebody in the dry part of Pulaski can send it to their business. Arkansas is one of the few states that has a total ban on shipping to business locations at all, and that does include how. So thank you for reminding me of that rule. Again, so many things out there. You need to remember them all at once, but there we go in Arkansas that strict prohibition on shipping to business locations at all. So unfortunately there, but, again, you know, these are the rules. If you do not like the rules, just one last reminder, talk to your consumers about encouraging them to petition, to lobby their their their legislators to change the rules, to make this more accessible, to make it more available, to make it less embarrassing on you. Legislators buy wine as well. You'll see that happen a lot where a legislator can't buy wine for their wine their daughter's wedding. Rules change next year. These things do move. And so this is just to say, you know, engage with different, industry groups, engage with free the rates, talk to your consumers if they have issues, and and we can try to work this into a much more available, amenable, still compliant, still responsible industry, that is able to service everybody as we can. But there we are. Thank you so much for staying over with me, for letting me ramble for over an hour. You are always such a fantastic audience, being so wrapped, having such great questions. I am so appreciative of you always, and I hope that you can join us again for our next webinars. We will have more information about those as soon as they are available. Again, should have things in the next couple months, and hope to see you again. Until then.