This blog was last updated on June 11, 2025
Effective July 1, 2025, all direct-to-consumer (DtC) shipments of wine into Maine must comply with the state’s beverage container redemption program, better known as a “bottle bill.”
While wine bottles sold in Maine retail stores have long been subject to these provisions, the state is extending the program to include DtC shipments from out-of-state wineries. This makes Maine the second state, after California, to apply its bottle bill to DtC shipments of wine.
Compliance with the bottle bill rule will require DtC shipping wineries to:
1) Register with the state
2) Ensure all labels they will ship into the state are registered with the Maine Department of Environmental Protection (DEP)
3) Collect the deposit amount on shipments to the state and
4) File an annual report to the state
Register as an Initiator of Deposit
Maine requires that beverages sold in the state that are subject to its bottle bill be handled by a registered Initiator of Deposit (IOD).
For wines that are sold in retail liquor stores, the IOD can be the wholesaler. However, for DtC-shipped wine, the IOD must be the licensed DtC shipping winery.
Further, Maine permits only one IOD for each registered label sold in the state. This means that while a winery can continue to work with a third-party IOD for wines they will only sell at wholesale in Maine, such as their distributor, all labels that the winery will sell both DtC and three-tier must be registered under the winery’s name. Wineries that are currently selling at three-tier in the state must therefore transfer IOD registration to them before they can ship those labels DtC.
- Registering as an IOD can be done online through the Maine DEP
- Instructions for first time registrants can be found here
- Questions about accessing the online portal can be addressed to A.Taylor@maine.gov
The annual fee for an IOD registration is $500 for wineries producing more than 50,000 gallons per year and $50 for smaller wineries.
IODs must contract with a comingling agent, which will be the in-state party that handles collection of containers and will remit the bottle bill collections to the state agencies. The state is still developing specific parameters for how DtC shippers will work with comingling agents. In the meantime, a list of available comingling agents can be found here.
Registering wine labels in Maine
Once the winery has registered as an IOD, they will need to register the labels they will DtC ship into the state through their DEP account.
Label registration can be done manually or through a CSV upload, and must list the product name, beverage and container type, glass color, UPC (if available) and comingling group information. Until July 15, 2025, brand label registrations will cost $1 per label.
Note that the bottle bill registration requirement for DtC-shipped wines is in no way associated with any brand/label registrations instituted by the Maine Bureau of Beverage and Lottery Operations. It remains the case that only wines sold through Maine wholesalers are subject to any BABLO label registrations.
How DtC wine shippers should collect the deposit
Wines subject to the Maine bottle bill must be properly labeled with a sticker that clearly identifies the IOD and the deposit value. Prior to sale in Maine, the IOD must provide a sample sticker to the DEP for approval, which will be subject to readability, suitability and durability.
The Maine deposit value is 15 cents per wine beverage container that is greater than 50 mL and 5 cents per container smaller than 50 mL (however, DtC shipments of wine in containers smaller than 250 mL is prohibited in Maine).
DtC shippers will need to collect the deposit value per bottle at the time of sale, listing the charge as a separate line item on their invoices. Notably, the deposit value is not subject to Maine’s sales tax.
Deposit remittance and annual reporting requirements
Unlike in California, the DtC wine shipper will not pay the deposit collections directly to the state. Instead, their comingling group is responsible for such remittances. As such, the comingling group will charge the winery for the deposit amount that must be remitted to the state along with additional handling and administrative charges, as set forth in their contract.
DtC wine shippers, as registered IODs, will still need to file an annual report (due in March) to the DEP reporting the number and type of containers sold in the state. There are different procedures depending on whether they are reporting actual or estimated sales data.
Managing container waste—and encouraging recycling—is a major concern for all states, with many latching onto bottle bills like Maine’s as one possible solution. While DtC wine shippers have long managed to escape the regulatory burden associated with bottle bills, the recent changes in California and Maine seem to signal that this will be a more common compliance requirement going forward.
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