This blog was last updated on December 16, 2024
California’s bottle bill got a major upgrade earlier this year, and it’s changed the rules for wineries, distilleries and beverage distributors in a big way. For the first time, wine and spirits manufacturers will need to register with CalRecycle, report sales and pay California Redemption Value (CRV) fees for containers sold or shipped to California.
The state’s push for sustainability has a direct impact on how the industry produces, labels and distributes beverages. Whether you sell directly from your tasting room, distribute through retailers or ship to California consumers, these changes demand attention. In this blog, we’ll break down the key updates and provide guidance to help your business prepare.
What’s new in the California bottle bill?
Effective January 1, 2024, the California bottle bill now includes wine and spirits containers, alongside beer, under its container deposit system. As a result, wineries and distilleries must comply with CRV registration, payment and reporting obligations. Beer, already included in the program, remains unchanged.
Another major update is set to go into effect on July 1, 2025. All wine and spirits containers sold in California must comply with California Redemption Value (CRV) labeling requirements.
Which containers are affected by the bottle?
All sales made within and/or shipped to retailers and residents in California are included in the bottle bill. This includes containers for wine, beer, malt beverages and spirits. The rules also extend to innovative packaging formats such as box, bladder, pouch or similar containers, ensuring that modern packaging doesn’t escape the recycling loop.
While beverages sold for on-site consumption in a tasting room are not subject to CRV reporting or fee payment, any sealed to-go containers sold from tasting rooms or shipped directly to consumers for off-site consumption must comply with all CRV requirements.
However, there are some exceptions. Products filled and labeled before January 1, 2024 are exempt from the new CRV labeling requirements. Additionally, wine and spirits sold for on-site consumption, such as those served in tasting rooms, are not subject to reporting or fee payment obligations.
What are California’s Cash Redemption Values?
The beverage container recycling rates in California are determined by container size and type. For containers smaller than 750 mL (less than 24 fluid ounces), the redemption value is 5 cents per bottle. Larger containers of 750 mL or more are subject to a 10-cent CRV per bottle. Non-traditional containers such as boxes, bladders and pouches carry a higher CA CRV of 25 cents per container.
California CRV Recycling Rates
| Bottle smaller than 750 mL (less than 24 fluid ounces) | CRV=5 cents per bottle |
| Bottles 750 mL or larger (24 fluid ounces or more) | CRV=10 cents per bottle |
| Boxes, bladders, pouches and similar containers | CRV=25 cents per container 00 |
Which businesses must register with CalRecycle?
All businesses that meet the bill’s definition of a “beverage manufacturer” or “distributor” must register through CalRecycle’s online portal. Understanding the associated roles and responsibilities is essential for businesses navigating the requirements.
Under the California bottle bill, a beverage manufacturer includes any entity that bottles, cans or fills beverage containers in California, holds a manufacturing license from the California Department of Alcoholic Beverage Control (ABC) or imports beverages for sale in the state. Third-party bottlers qualify as manufacturers only if they both fill and sell the containers, although reporting and fee obligations can be transferred to producers through Pay on Behalf agreements.
Out-of-state wineries and distilleries shipping exclusively to California importers are exempt from registration, as the importer assumes responsibility for fees. However, those shipping directly to California consumers may need to register as both Beverage Manufacturers and Distributors.
Beverage manufacturers must now report and pay CRV and processing fees for all containers sold or transferred, even if these were filled and labeled before this date. Processing fees vary based on the container material, with the 2024 fee for glass containers set at $0.00576 per unit. These fees, along with CRV payments, are to be submitted monthly as of March 10, 2024.
A distributor, on the other hand, is any entity that sells or imports beverages in qualifying containers to California dealers, consumers or producers. This includes businesses holding an ABC direct shipper permit. Registration ensures compliance with reporting and payment obligations under the updated bottle bill, and companies operating multiple brands may consolidate registrations under a single federal tax ID when applicable.
Distributors are also subject to reporting and paying CRV fees. They are allowed to retain a 1.5% administrative fee to cover their costs. Smaller businesses may qualify for annual payment schedules, provided they fall below specific thresholds for annual CRV and processing fees. Importantly, costs can be passed on to consumers, who can redeem their bottles at recycling centers to recover the CRV.
Consequences of non-compliance
Failure to adhere to California’s bottle bill regulations can result in serious penalties, including fines, suspension of licenses or permits and even revocation of business licenses. These consequences underscore the importance of compliance and timely action to meet the new requirements.
With the changes already well underway, now is the time to act. Businesses should:
- Register with CalRecycle as a beverage manufacturer or distributor.
- Update labels to meet the 2025 CRV requirements.
- Implement systems to manage reporting and payment obligations.
Take a deeper dive into the implementation of California’s bottle bill and explore other regulatory changes in our exclusive, on-demand webinar, ‘Regulatory Opportunities and Challenges in DtC Shipping Across the States’.
This informational blog does not constitute legal advice. Reach out with specific questions about your business’s responsibilities under California’s bottle bill.
About Gillian Garrett
Gillian is the founding member of Gillian Garrett Law, PC. She advises and represents alcohol beverage industry clients on California and federal alcohol law. She can be reached at gilliangarrettlaw.com.
