August 16, 2026 · WineCompliance.ai
Michigan Sent 182 Cease-and-Desist Letters Last Year: What Its Enforcement Report Tells Wineries
Michigan's Liquor Control Commission investigated 121 out-of-state entities, cited 47 licensees for expired direct shipper licenses, and sent 182 cease-and-desist letters in fiscal year 2025. Here's what its own enforcement report says about how it catches violators and what trips up otherwise-compliant wineries.
Michigan's Liquor Control Commission (MLCC) investigated 121 out-of-state entities through undercover purchases in fiscal year 2025, found 60 of them unlicensed, and the state's Attorney General sent 182 cease-and-desist letters to 92 entities. The state publishes this data every year in a mandated report, and it names the exact mistakes that get licensed wineries cited too: expired licenses, missing invoices, unlabeled boxes, and over-shipping the 13,500 liter annual cap.
Key takeaways
- Michigan uses two enforcement tools: undercover test purchases and quarterly common carrier report audits from FedEx and UPS.
- In fiscal year 2025, 47 already-licensed shippers were cited for shipping on an expired direct shipper license, not for lacking one entirely.
- The most common violations among licensed wineries were failing to register products, skipping age verification, missing invoices, unlabeled shipping boxes, and exceeding the 13,500 liter (1,500 case) annual cap.
- Cease-and-desist letters are step one. Wineries that keep shipping after a letter have faced federal lawsuits under the Twenty-First Amendment Enforcement Act with fines up to $25,000 per violation in past Michigan cases.
- Unlawful shipment is a felony in Michigan, punishable by up to 4 years imprisonment or a $5,000 fine, or both.
How Michigan actually catches violators
The Illegal Shipment of Wine Report for 2026 contains reporting requirements mandated pursuant to Section 401 of Public Act 22 of 2025, Article 10. It documents exactly how the MLCC's 13 enforcement staff spend their time and what they find.
Test purchases. One-Hundred twenty-one (121) out-of-state entities were investigated by the MLCC through online purchases. Sixty (60) of these entities were identified as being unlicensed. Investigators bought 99 bottles from unlicensed sellers, representing 74,250 milliliters of alcohol shipped illegally, and that resulted in sixty (60) requests to the Michigan Office of Attorney General to send cease & desist letters to these unlicensed entities. They also bought 70 bottles from already-licensed entities to test whether those were following the rules.
Mark Vanneste, an attorney at Howard & Howard who covers Michigan wine law, describes the pattern in plain terms: an MLCC investigator will place an order on an out-of-state retailer's website or order wine from an unlicensed, out-of-state winery. The MLCC investigator pays for the wine and shipping and then waits to see if the out-of-state seller processes the order and ships the wine. If the out-of-state seller follows through and ships the wine to the MLCC investigator, the Michigan Attorney General's office will normally send a cease-and-desist letter.
Carrier report audits. The report is explicit that this is a growing focus. MLCC continues to focus on reviewing common carrier reports that indicate wine shipments directly to Michigan consumers. The reports are required to be submitted to MLCC quarterly detailing all deliveries of alcohol into the state of Michigan. Reports are received from both Federal Express and United Parcel Service. These reports outline the details of thousands of deliveries. After cross-checking those against license and product registration records, MLCC forwarded an additional sixty-one (61) requests to the Michigan Office of Attorney General to send cease & desist letters to these unlicensed entities.
That two-pronged approach (buy a bottle, then check the shipping data) is standard practice nationally. As SevenFifty Daily notes, whereas stings provide qualitative evidence of noncompliance, carrier reports offer regulators quantitative proof of illegal shipments to consumers, and agency investigators audit these reports and compare their shipping data against shipping data from those reports required to be filed by direct shippers, which are typically wineries. The mismatches between the two sets reveal a portion of those shipments that are unauthorized.
Follow-up matters too. After a cease-and-desist letter goes out, follow up attempts to purchase alcohol were conducted on entities who received cease & desist letters from the Michigan Office of Attorney General. The outcomes varied widely: some sellers amended website to reject sales and shipments of wine to Michigan, others applied for and received the required direct shipper license, and at least one made no change to shipping practices and again shipped wine to Michigan, which the report says gets referred for a Twenty-First Amendment lawsuit.
What trips up wineries that already have a license
The headline numbers about unlicensed shippers get the attention, but the report's most useful section for a compliant DTC manager is the list of violations found among licensees. The MLCC followed up with all licensees that failed to renew their direct shipper license for the 2025 fiscal year. A total of forty-seven (47) licensees were cited with violations for shipping wine into Michigan without an active direct shipper license. These are not unlicensed operators, they are wineries who let a renewal lapse and kept shipping anyway.
Beyond expired licenses, the report lists specific administrative violations that resulted in fines: failure to register products, failure to verify age at time of purchase and delivery, failure to include an invoice in box, failure to properly label the shipping box (stating it contains alcohol and must be delivered to 21+), over shipping (excess of 13,500 liters) of wine annually, and "use or benefit" of a liquor license.
That cap is a winery-level aggregate, not a per-order or per-customer limit, and it applies across commonly owned or managed labels combined, so a group running two or three brands under one ownership structure needs to track shipments as one pool, not three separate ones.
When a letter turns into a lawsuit
A cease-and-desist letter is Michigan's opening move, not its only one. Michigan's Attorney General has litigated this pattern repeatedly. In 2020, the state sued Vintner's Collective, a California retailer, after it kept shipping following a warning. Court filings describe the sequence: the cease and desist letter informed Vintner's Collective that its practice of directly shipping wine to consumers in the State of Michigan without possessing a direct shipper license is illegal. Furthermore, the cease and desist letter stated that legal action would result if Vintner's Collective continued its illegal activity. The company initially agreed to stop, then failed to comply with the cease and desist request, and the state filed suit.
In 2022, Michigan settled with three California companies that had ignored earlier warnings: Vinoce Vineyards, LLC, $25,000 fine; Beverly Hills Liquor & Wine, $12,500 fine; and Cellar Collections Inc., $10,000 fine. More recently, the Michigan Beer & Wine Wholesalers Association highlighted cases against Pellegrini Vineyards and Tsillan Cellars, noting that despite receiving cease and desist letters from the Attorney General's office, investigators confirmed illegal shipments from both Pellegrini Vineyards and Tsillan Cellars through undercover purchases. As of that association's count, her office has pursued 37 lawsuits, four of which are pending, resulting in multiple injunctions and significant fines.
Vanneste's summary of what the state typically asks for in these suits is worth repeating for anyone tempted to treat a cease-and-desist letter as a formality: The Attorney General usually requests a penalty of $25,000 for each violation or shipment, an order permanently enjoining the seller from violating Michigan law in the future, reimbursement of investigative expenses, and reimbursement of costs and attorney fees. That's on top of the criminal exposure the state now spells out directly in every notice it sends: making unlawful shipments of wine into this state may be a felony punishable by imprisonment for not more than 4 years or a fine of not more than $5,000.00, or both.
Pre-flight checklist before you ship into Michigan
Run through this before every shipping season, not just once at licensing time:
- Confirm your direct shipper license is current. Renewal is $100 annually and it's easy to let lapse if it's not on someone's calendar; 47 licensees got cited for exactly this in one year.
- Check every label is registered in SIPS+. New vintages and new SKUs need registration before they ship, not after.
- Verify your box labeling. The shipping container needs a clear statement that it contains alcohol and requires an adult signature 21 or older.
- Include the invoice inside the box. A packing slip that lists brand and quantity satisfies this; an empty box with just a shipping label does not.
- Track your running total against 13,500 liters. If you operate multiple commonly managed labels, combine their Michigan shipments into one running count.
- Confirm the destination isn't a dry township. Michigan has local dry areas, so a shipment can be otherwise fully compliant and still be unlawful at a specific address.
- Keep your quarterly excise tax and volume reports current. These are the same records MLCC compares against carrier data.
Our track license renewal dates and running volume caps by state, which is exactly the kind of gap this report shows getting wineries cited.
Frequently asked questions
What happens after Michigan sends a cease-and-desist letter?
The MLCC typically follows up with another test purchase or a carrier report check to see whether the seller stopped shipping. If shipments continue, the case is referred to the Attorney General, who can file a federal lawsuit under the Twenty-First Amendment Enforcement Act seeking injunctions, fines, and reimbursement of costs.
Is shipping wine into Michigan without a license actually a felony?
Yes. Michigan's notices to unlicensed shippers state plainly that making unlawful shipments of wine into this state may be a felony punishable by imprisonment for not more than 4 years or a fine of not more than $5,000.00, or both. In practice, most enforcement to date has resulted in civil fines and injunctions rather than criminal charges, but the criminal exposure is real and stated in every notice.
Does the 13,500 liter cap apply per customer or per winery?
It's a winery-level aggregate cap, not a per-customer limit. Under Michigan law, a direct shipper cannot ship more than 1,500 nine-liter cases, or 13,500 liters, of wine to all Michigan consumers combined in a calendar year, and commonly managed or commonly owned labels have to combine their totals rather than each getting a separate cap.
Can an out-of-state retailer ship wine to Michigan consumers?
No. Only licensed wine manufacturers, in-state or out-of-state, can hold a Michigan direct shipper license. Out-of-state retailers that do not manufacture wine are prohibited from shipping directly to Michigan consumers regardless of licensing status.
What if my direct shipper license expired but I didn't notice?
You're still liable. The report shows Michigan actively cross-checks its licensee list against carrier shipment data, and 47 licensees were cited in one year for shipping on an expired license rather than for never having one.
Sources
This article is general information, not legal advice. Verify current requirements with the state agency or your compliance provider before shipping.
- Michigan
- DTC Shipping
- Compliance
- Enforcement
- Direct Shipper License
This is general information, not legal advice — verify with your compliance provider before shipping.