Tax Guide for Alcoholic Beverage
Beginning January 1, 2023 there are several changes to the Alcoholic Beverage Tax Program (Senate Bill 518 [Stats. 2022, ch. 702]), including:
- All alcoholic beverage account holders are required to file online.
- Any information contained in winegrower returns and supplemental schedules filed on or after January 1, 2023, shall be made public upon request, including names and addresses except the names and addresses of natural persons.
- Taxpayers may elect to prohibit the disclosure of the information contained in their winegrower return and schedules. The winegrower return will be updated to include a designated checkbox where the taxpayer may elect to prohibit disclosure.
Please continue to check back for more updates to our website. We will send notices to affected account holders soon.
Helping your business succeed is important to the California Department of Tax and Fee Administration (CDTFA). The taxes you collect and pay to the state help fund state and local services and programs that are important to you and your community.
Understanding the tax issues and registration requirements specific to the alcoholic beverage industry can be time-consuming and complicated, so it is important that you get the information you need in a timely and understandable way, helping you focus on starting and growing your business.
This guide is provided to help you better understand the tax obligations for sellers, manufacturers, and importers of alcoholic beverages.
How the Revenue is Used
Revenues from the tax are deposited into the Alcohol Beverage Control Fund and are withdrawn for use by the state's General Fund or used to pay refunds under this program.
How to Use This Guide
Each section of this guide contains important information relevant to your alcoholic beverage business.
The Getting Started tab provides key resources related to registration, filing returns, account maintenance, and other important information you need.
The Industry Topics tab contains specific topics important to the alcoholic beverage industry.
The Resources tab provides links to useful information, including special notices, other relevant industry guides, publications, and statutory and regulatory information.
If You Need Help
See the How to Contact Us page for contact information.
If you have suggestions for improving this guide, please contact us via email.
Application of Tax
The alcoholic beverage tax is a per-gallon excise tax collected on the sale, distribution, or importation of alcoholic beverages in California. The CDTFA collects the tax and administers the program in cooperation with the Board of Equalization.
In general, you must register with us if you are required to obtain one or more of the following licenses issued by the California Department of Alcoholic Beverage Control (ABC). After you apply with ABC, we will notify you of which CDTFA Alcoholic Beverage Tax Account type you are required to register for.
- Beer Vendor (Certificate of Compliance Holder)
- Craft Distiller
- Customs Broker
- Distilled Spirits Manufacturer's Agent
- Importer (Beer and Wine; Beer and Wine Importer's General, Brandy, and Distilled Spirits)
- Industrial Alcohol Dealer
- Manufacturer (Beer, Small Beer, Brandy, and Distilled Spirits)
- On-Sale General for Airplanes
- On-Sale General for Boats
- On-Sale General for Trains
- Public Warehouse
- Rectifier (Distilled Spirits, Wine)
- Wholesaler (Distilled Spirits, Brandy)
- Wine Blender
- Wine Direct Shipper
- Effective November 9, 2020, new public warehouse license holders (Type 14) must register with us for a public warehouse account.
In addition, all common carriers, except railroads and steamship companies, must also register with us in order to transport alcoholic beverages into California.
You must also register for a seller's permit and file sales and use tax returns with us. For more sales and use tax information, review the industry guides below that relate to the alcoholic beverage product you sell.
To register for your alcoholic beverage account, a seller's permit, any other permit, license (cigarette, tobacco, or fuel), or account with the CDTFA, visit our online registration page.
If you have questions, please contact our Customer Service Center at 1-800-400-7115 (CRS:711), Monday through Friday, 7:30 a.m. to 5:00p.m., (Pacific time), except state holidays.
Updating Your Business Information
Go to www.cdtfa.ca.gov, login with your username and password to update your account information including, but not limited to, selling your business, changing your mailing address, email address, or telephone number, or closing your business. If you prefer, you may use form CDTFA-345-SP, Notice of Business Change, Special Taxes and Fees Accounts, to notify CDTFA of changes. It is important to notify us so we can update our records to ensure you receive information, email reminders to electronically file, and other updates timely.
You may also contact CDTFA Customer Service Center at 1-800-400-7115 (TTY: 711) and select the option for Special Taxes and Fees or send a message through our website at Email Your Tax Questions.
Visit the tax rate page to view current and historical alcoholic beverage tax rates.
Filing Returns and Reports
All alcoholic beverage tax returns, supplemental schedules, and reports are required to be filed online. We have developed Microsoft Excel templates to help you file your alcoholic beverage supplemental schedules and reports using our online services system. For more information about online filing and to obtain these Excel templates, see our Online Filing tab. You will be able to attach (upload) the completed Excel file when you file your return or report online.
You must file all applicable alcohol beverage tax returns, supplemental schedules, and reports even if no transactions were made during the reporting period or if no tax is due for the reporting period.
Returns and Supplemental Schedules
Every licensed beer manufacturer is required to file a tax return and supplemental schedule (if applicable) on or before the 15th of the month following the reporting period. For example, a return for January is due on or before February 15th.
- Beer Manufacturer Tax Return
- CDTFA-269-BM, Beer Imported into California Schedule
Beer and Wine Importer
Every licensed beer and wine importer is required to file a tax return and supplemental schedule (if applicable) on or before the 15th of the month following the reporting period. For example, a return for January is due on or before February 15th.
- Beer & Wine Importer Tax Return
- CDTFA-269-BW, Beer and Wine Imported into California Schedule
Winegrower, Wine Direct Shipper, and Wine Blender
Every licensed winegrower, wine direct shipper, or wine blender is required to file a tax return and supplemental schedule (if applicable) on or before the 15th of the month following the reporting period. For example, a return for January is due on or before February 15th.
- Winegrower Tax Return
- CDTFA-269-WG, Wine Imported into California Schedule
Beginning with the January 2023 returns, California law requires any information contained in winegrower returns and an accompanying supplemental schedule to be made public upon request. This includes names, addresses, and reported amounts. For those taxpayers filing as natural persons (such as a sole proprietor or partnership), your name and address will be redacted (Revenue and Taxation Code, section 32457.1 [added by Stats 2022, ch.702]).
The law also provides that taxpayers may elect to prohibit the disclosure of their return and accompanying schedule information. Additional information and a checkbox allowing you to keep your return and schedule information confidential will be added to the winegrower online return beginning with the January 2023 filing period. Taxpayers electing to keep their information confidential must use the checkbox on each winegrower return filed to prevent disclosure.
Disclosure of Winegrower Returns and Schedules Information
If you would like to make a request for the disclosable information contained in the winegrower returns and accompanying schedules in accordance with Revenue and Taxation Code section 32457.1, please contact the State Board of Equalization (BOE).
Please submit your request to BOE’s Legal Department by email at BOEPRArequests@boe.ca.gov, or by mail at:BOE Legal Department, MIC: 121
PO Box 942879
Sacramento, CA 94279-0121
Please include the following relevant information in your email request:
- Account number(s),
- Business name(s), or
- Business address(es), among others.
Please note, some taxpayers may elect to keep their tax return and accompanying schedule information confidential. As such, some information may not be available for disclosure.
Distilled Spirits Manufacturer/Importer
Every distilled spirits manufacturer/importer is required to file a tax return and supplemental schedules (if applicable) on or before the 15th of the month following the reporting period. For example, a return for January is due on or before February 15th.
- Distilled Spirits Tax Return
- CDTFA-240-DS, Distilled Spirits Transaction Schedules include:
- 240-A, Distilled Spirits Received From Own Bottling Department
- 241-A, Distilled Spirits Purchased or Received from Other Licensed Distilled Spirits Manufacturers/Importers in California
- 242-A, Distilled Spirits Imported into California
- 243-B, Claim for Distilled Spirits Excise Tax Exemption on Sale or Delivery to Other Licensed Distilled Spirits Manufacturers/Importers in California
- 244-B, Claim for Excise Tax Exemption on Distilled Spirits Exported or Sold to Common Carriers and/or Armed Forces Instrumentalities
- CDTFA-240-DS, Distilled Spirits Transaction Schedules include:
Distilled Spirits Common Carrier
Each common carrier engaged in interstate or foreign passenger service making sales of distilled spirits in California and every person licensed to sell distilled spirits aboard such a carrier, is required to file a tax return on or before the first day of the second month following the reporting period. For example, a return for January is due on or before March 1st.
- Common Carriers Tax Return
Alcoholic Beverage Common Carrier
Common carriers and holders of interstate alcoholic beverage transporters' permits transporting alcoholic beverages into the state are required to file a report on or before the 15th of each month of all deliveries of alcoholic beverages made during the preceding calendar month. For example, a report for all deliveries of alcoholic beverages made during January is due on or before February 15th.
- CDTFA-217, Common Carrier's Report of Delivery
Each holder of a California Certificate of Compliance issued pursuant to section 23671 of the Business and Professions Code and section 32452 of the Revenue and Taxation Code is required to file a report on or before the 10th of each month following the reporting period, of all shipments of beer into California during the preceding calendar month. For example, a report for all shipments of beer into California during January is due on or before February 10th.
- CDTFA-1056, Vendor's Report of Beer Shipments into California
Alcoholic Beverage Customs Broker
Each customs broker of alcoholic beverages is required to file a report on or before the 15th of each month following the reporting period of all transactions of alcoholic beverages into California during the preceding calendar month. For example, a report for all transactions of alcoholic beverages into California during January is due on or before February 15th.
- CDTFA-1096, Customs Broker's Report of Transactions
Public Warehouse License Holder
“Public warehouse” means any location licensed for the storage of, but not the sale of, alcohol or alcoholic beverages for the account of other licensees and includes United States custom bonded warehouses and United States internal revenue bonded warehouses when the bonded warehouses are used for storage of alcoholic beverages for the account of another licensee (Business and Professions Code section 23036).
Every licensed public warehouse (Type 14) is required to complete and file a report on or before January 15th and July 15th of each year, reporting all distilled spirits held in storage, in bottled form, at the close of business on December 31st and June 30th. A report must be filed even if there is no activity to report.
- CDTFA-506-PW, Public Warehouse Distilled Spirits Inventory Report
When filing online, you are able to file and pay your alcoholic beverage tax due in one transaction. You may also visit our website to conveniently make a payment or learn about our various payment options. Payments must be submitted by the due date to be considered timely.
Taxpayers with an estimated average monthly tax liability of $20,000 or more are required to pay amounts due by electronic funds transfer (EFT). We will notify you in writing if you are required to pay your taxes electronically using one of the available EFT payment options. If you are required to make your payments by EFT and you initiate your payment on the tax due date, you must complete your transaction by 3:00 p.m. Pacific time to ensure your funds are deposited into CDTFA's bank account by the next banking day.
Penalty and Interest
The following penalty charges may be assessed for filing a late return and/or late payment:
- Late-file penalty – Fifty dollars ($50) if the tax return is not filed by the due date.
- Late-pay penalty – Ten percent (10%) of the tax amount due if the tax is not paid by the due date.
- Late-file and late-pay penalty – Ten percent (10%) or fifty dollars ($50), whichever is greater, if the tax return is not filed and paid by the due date.
Interest also applies to the late payments for each month or fraction of a month that the payment is late (Revenue and Taxation Code section 32252).
Alcoholic Beverage Tax Online Filing
We have developed Excel templates for several alcoholic beverage tax forms. For instructions on completing alcoholic beverage tax returns, supplemental schedules, and reports, please refer to our Online Filing Instructions web page.
If you receive an error message when opening your template using our Online Services system, you may click “Yes” to open or switch your internet browser to Google Chrome and avoid this error message.
Online Filing – Downloadable Excel Templates
- The applicable Excel templates are available when you log in to file your return or report online.
- Download the applicable Excel template(s) when you log in to file your return or report online.
- Read the Template Instructions tab before completing the supplemental schedule or report.
- Save the Excel file to your computer once you complete it. We recommend saving the file to your desktop or designated file/folder. If you are using an Apple computer, you will need to save the file in Numbers then Export To an Excel file.
- Go back to the Online Services Initial Questions screen and click the Upload Schedule or the Upload Report button to bring up the dialog box.
- Click the Choose File button in the dialog box to find the saved file on your desktop or designated file/folder.
- Click the Upload button in the dialog box to populate your template entries.
- Check out our online services webpage and select the Tutorials tab to view our “How To” videos.
This functionality may not be available for Apple products. If you are unable to upload your workbook, you can manually complete your schedule/report in your online return and submit your completed return by the required due date.
|Type of Filer||Alcoholic Beverage Tax Form Title||Alcoholic Beverage Schedule/Report Form||Excel Template|
|Alcohol Beverage Common Carrier||N/A||CDTFA-217 Common Carrier's Report of Delivery||CDTFA-217-Template|
|Distilled Spirits Manufacturer/Importer||Distilled Spirits Tax Return||Distilled Spirits Received From Own Bottling Department (Schedule 240-A)||CDTFA-240-DS-Template|
|Distilled Spirits Purchased or Received from Other Licensed Distilled Spirits Manufacturers/Importers in California (Schedule 241-A)||CDTFA-240-DS-Template|
|Distilled Spirits Imported into California (Schedule 242-A)||CDTFA-240-DS-Template|
|Claim for Distilled Spirits Excise Tax Exemption on Sale or Delivery to Other Licensed Distilled Spirits Manufacturers/Importers in California (Schedule CDTFA-243-B)||CDTFA-240-DS-Template|
|Claim for Excise Tax Exemption on Distilled Spirits Exported or Sold to Common Carriers and/or Armed Forces Instrumentalities (Schedule CDTFA-244-B)||CDTFA-240-DS-Template|
|Beer Manufacturer||Beer Manufacturer Tax Return||CDTFA-269-BM Beer Imported into California||CDTFA-269-BM-Template|
|Beer and Wine Importer||Beer & Wine Importer Tax Return||CDTFA-269-BW Beer and Wine Imported into California||CDTFA-269-BW-Template|
|Winegrower, Wine Direct Shipper, and Wine Blender||Winegrower Tax Return||CDTFA-269-WG Wine Imported into California||CDTFA-269-WG-Template|
|Beer Vendor||N/A||CDTFA-1056 Vendor's Report of Beer Shipments into California||CDTFA-1056-v2-Template|
|Alcoholic Beverage Customs Broker||N/A||CDTFA-1096 Customs Broker's Report of Transactions||CDTFA-1096-Template|
|Public Warehouse License Holder||N/A||CDTFA-506-PW Public Warehouse Distilled Spirits Inventory Report||CDTFA-506-PW Template|
- For reporting periods November 2020 and after.
Below are some key definitions for the alcohol beverage industry:
"Beer" means any alcoholic beverage obtained by the fermentation of any infusion or decoction of barley, malt, hops, or any other similar product, or any combination thereof in water, and includes ale, porter, brown, stout, lager beer, small beer, and strong beer, but does not include sake, known as Japanese rice wine. Beer may be produced using the following materials as adjuncts in fermentation: honey, fruit, fruit juice, fruit concentrate, herbs, spices, and other food materials. Beer aged in an empty wooden barrel previously used to contain wine or distilled spirits shall be defined exclusively as "beer" and shall not be considered a dilution or mixture of any other alcoholic beverage. (Business and Professions Code section 23006)
"Wine" means the product obtained from normal alcoholic fermentation from sound ripe grape juice or other agricultural products containing natural or added sugar or any such alcoholic beverage which is added grape brandy, fruit brandy, or spirits of wine, which is distilled from the particular agricultural product or products the wine is made from and other rectified wine products and by whatever name and which does not contain more than 15 percent added flavoring, coloring, and blending material and alcohol by volume no more than 24 percent, and includes vermouth and sake, known as Japanese rice wine. (Business and Professions Code section 23007)
"Distilled spirits" means an alcoholic beverage obtained by the distillation of fermented agricultural products, and includes alcohol for beverage use, spirits of wine, whiskey, rum, brandy, and gin, including all dilutions and mixtures thereof. "Distilled spirits" does not include "powdered alcohol," as defined in Business and Professions Code section 23003.1. (Business and Professions Code section 23005)
General Tax Application
The following are general applications for the alcoholic beverage tax:
Beer and wine
The excise tax on beer and wine is generally paid by manufacturers, wine growers, and importers. Sellers of beer and wine must pay the excise tax if the tax was not paid by the manufacturers, winegrowers, or importers. Beer and wine is presumed to be sold, and the alcoholic beverage tax is due when it leaves a manufacture's facility or is removed from internal revenue bonded premise, unless:
- It was sold and delivered in internal revenue bond to another beer manufacturer or wine grower in California.
- It was exported or sold for export and actually exported from California.
- The sale is otherwise exempt.
In general, the excise tax on distilled spirits is paid by distilled spirits wholesalers based on sales to in-state retailers. Sellers of distilled spirits must pay the excise tax if the tax was not paid by the wholesaler. Distilled spirits are presumed to be sold, and the alcoholic beverage tax is due when they are sold to in-state retailers or to consumers if sold by licensed craft distillers, unless the distilled spirits:
- Are still in the possession of the licensee.
- Have been sold or delivered to another licensed distilled spirits manufacturer, rectifier, importer, or wholesaler.
- Have been exported outside of California, or sold for export by the licensee and actually exported from California within 90 days from the date of sale.
- Have been lost through unintentional destruction prior to the termination of possession.
- Have been lost through an unaccounted for loss prior to the termination of possession. The unaccounted for loss shall not exceed the tolerance set forth in section (b) of Regulation 2550, Destruction and Unaccounted For Losses of Distilled Spirits.
- Are otherwise exempt from taxation. See the “General Exemptions” section below.
Tax Credits Allowed
Tax credits may be allowed for:
- Beer or wine subsequently exported outside California or destroyed (maintain documentation to support the exemption/credit); and
- Distilled spirits sold to certain persons holding a permit under federal law and who use the distilled spirits in food products.
The following are exempt from the alcoholic beverage tax:
- Alcoholic beverages traveling through California destined for outside the state.
- Certain sales of alcohol, distilled spirits, or wine for use in trades, professions, or for industrial purposes, and not for beverage purposes (Business and Professions Code sections 23111, 23112, and 23113). See section below for more information regarding alcohol beverages sold for industrial purposes.
- Distilled spirits, beer, and wine sold for export and actually exported.
- Sales of alcoholic beverages to certain commercial carriers of persons when beverages will be used on their facilities outside California.
- Sales of distilled spirits by brandy manufacturers, distilled spirits manufacturers, rectifiers, importers, and distilled spirits wholesalers to U.S. Army, Air Force, Navy, Marine Corps, or Coast Guard exchanges, officers' clubs, noncommissioned officers' and enlisted men's clubs, or messes located in California.
Distilled Spirits and Wine Sold for Industrial Uses
There is an alcoholic beverage tax exemption on the sale of alcohol, distilled spirits, or wine by distilled spirits manufacturers, brandy manufacturers, rectifiers, industrial alcohol dealers, or winegrowers for industrial uses, but only when sold in packages with a capacity larger than one gallon (Revenue and Taxation Code sections 32052 and 32053).
Alcohol, distilled spirits, or wine used in the manufacture of any of the following is considered an industrial use, if the products are unfit for consumption as a beverage (Business and Professions Code section 23112):
- Medicinal, pharmaceutical, or antiseptic products (such as hand sanitizer), including prescriptions compounded by registered pharmacists
- Toilet products
- Flavoring extracts
- Sirups (Syrups)
- Food products
- Scientific, chemical, or industrial products
|Alcoholic Beverage Tax Form||Associated line|
|Distilled Spirits Tax Return||Line: Other exemptions|
|Winegrower Tax Return||Line: Federal tax-paid wine sold for industrial use|
|Beer & Wine Importer Tax Return||Line: Other exemptions|
Destruction of Spoiled Beer and Wine
As a registered beer and wine importer, beer manufacturer, or winegrower, you are allowed an alcoholic beverage tax exemption or credit for spoiled beer or wine destroyed under the supervision of a CDTFA representative, only after prior written approval is received (Revenue and Taxation Code section 32176). An exemption or credit may be taken for the following:
- An exemption on spoiled beer or wine that has not yet been sold in California
- A credit on tax-paid beer or wine that was sold in California, subsequently spoiled, and then returned to you by the wholesalers.
|Alcoholic Beverage Tax Form||Associated line|
|Beer Manufacturer Tax Return||Line: Federal tax-paid beer destroyed as stated in R&TC 32176 (b)|
|Winegrower Tax Return||Line: Other exemptions|
|Beer & Wine Importer Tax Return||Line: Spoiled beer
Line: Spoiled wine
Unsupervised Destruction—Beer and Wine Importers
Beer and wine importers can claim a credit for destruction of small quantities of tax-paid beer or wine without CDTFA supervision. However, you must receive written approval from us prior to destroying the wine to claim the exemption or credit. (Regulation 2552).
For the purposes of unsupervised destruction, “small quantities” means the following:
- The quantity of beer destroyed is 2,500 gallons or less, or
- The quantity of still wine destroyed is 2,500 gallons or less, or
- The quantity of champagne or sparkling wine destroyed is 1,500 gallons or less.
If you don't qualify for unsupervised destruction as noted above, you may still be eligible to claim an exemption or credit on tax-paid beer or wine that is destroyed with supervision (Revenue and Taxation Code section 32176). We will contact you regarding the appropriate type of supervision required to claim your exemption or credit after you complete and submit form CDTFA-775.
Submitting a Beer or Wine Destruction Approval Request
To submit a destruction request, a beer and wine importer, beer manufacturer, or winegrower must submit form CDTFA-775, Application for Approval and Declaration of Destruction for Spoiled Beer or Wine The steps below outline the process for a destruction request:
- Complete form CDTFA-775 Sections I and II and email it to CDTFA775@cdtfa.ca.gov. On the subject line of the email, include the following: Destruction Approval Request – CDTFA Account (input account number).
- We will review your request and determine whether your beer and/or wine qualifies for an unsupervised destruction or if supervision by a CDTFA representative is required. We will contact you if additional information is needed prior to approval.
- If your request is:
- Approved – We will complete Sections III and IV (if applicable). The approval process generally takes up to three business days; however, if an appointment with a CDTFA representative is needed the process can take up to 12 business days. Once approved, the form will be available on your online services profile at the account level under the unread messages.
- Not approved – We will contact you and CDTFA-775 form will not be returned to you.
All exemptions or credits claimed are subject to verification and may be disallowed for improper destruction and/or insufficient documentation.
Bringing Alcoholic Beverages into California by US Military Personnel for Personal or Household Use
The California Department of Alcoholic Beverage Control (ABC) regulates the manufacturing, importing, and sales of alcoholic beverages in California. We collect the alcoholic beverage excise taxes from persons that are required to be licensed with ABC and not from consumers, unless ABC determines that the consumer is required to be licensed with them. The California Business and Professions Code section 23661(e) exempts military personnel from the California licensing requirements when importing alcoholic beverages into California for personal or household use.
For information and requirements regarding the importing of alcohol beverages into California, we recommend that you read ABC article, Importing Alcoholic Beverages for Personal or Household Use which can be found on ABC's website. This article includes a section for military personnel.
Even though you may not owe the California alcoholic beverage excise tax on your alcoholic beverages, you may owe California use tax based on your purchase price of the alcoholic beverages that you bring into California for consumption. Please see our guide on Use Tax for more information.
You must maintain your records for at least four years from the time the tax is due at your licensed premises unless we give you written authorization to keep them at another location or destroy them sooner. For additional information regarding record retention, please see Regulation 4901.
Need to know more? Follow the links below for more information about the topics covered in this guide, as well as other information you might find helpful:Open All Close All
Laws and Regulations
- Special Notice – Updates to Your Winegrower Return Beginning January 1, 2023
- Special Notice – Alcoholic Beverage Tax – Online Filing Required Beginning January 1, 2023
- Revisions to the Public Warehouse Distilled Spirits Inventory Report and Launch of Online Filing Effective November 9, 2020
- Update to Postal Code Abbreviation Table Effective May 2020 Filing Period
List of Licensees for Reporting Purposes
A list of current licensees can be obtained by visiting our Online Services homepage under the Registration section.
Other Helpful Resources
- Contact Us – A listing of California Department of Tax and Fee Administration (CDTFA) contacts for your questions and concerns.
- Sign Up for CDTFA Updates – Subscribe to our email lists and receive the latest news, newsletters, tax and fee updates, public meeting agendas, and other announcements.
- Special Notices – CDTFA special notices are issued whenever there is a change in law, tax rates, or CDTFA procedures.
- CDTFA Online Services – Learn about the online services CDTFA offers.
- CDTFA Field Offices – A comprehensive listing of all CDTFA offices and contact information.
- Get It In Writing! – Tax and Fee Laws can be complex, and you are encouraged to put your tax questions in writing. You may also send your request in a letter to: Program Administration Branch, MIC; 31, California Department of Tax and Fee Administration, P.O. Box 942879, Sacramento, CA 94279-0031.
- Taxpayers' Rights Advocate (TRA) – The TRA Office helps taxpayers when they are unable to resolve a matter through normal channels, when they want information regarding procedures, or when there are apparent rights violations.