Wineries and Distilleries Must Register for the CA Bottle Bill Now

Alex Koral
October 16, 2023

This blog was last updated on October 16, 2023

On January 1, 2024, wines and spirits sold in California will become subject to the state’s Container Recycling and Litter Reduction Act, or bottle bill. As the effective date draws near, wineries and distilleries selling in California need to prepare themselves for the new requirements. (Beer and low-ABV mixed drinks were already part of the Act.)

The bottle bill is designed to encourage recycling by providing a rebate to consumers who bring their used containers to a certified recycling center, and California is just one of several states with such a program.

While most of the provisions of the bottle bill, including collection and remittance of the California Redemption Value (or CRV, the 5, 10 or 25 cent deposit), cannot be acted on until after the start of the new year, there is one essential step that suppliers selling in the state should do sooner than later: registration with CalRecycle, the state’s department managing recycling.

All California-based manufacturers, Certificate of Compliance holders and Direct Shipper Permittees will need to register with CalRecycle as a “manufacturer.” Manufacturers, as defined by the bottle bill, do not collect the CRV from consumers but must still report the amount of subject containers they sell in the state and pay a small fee ($0.00452) per container.

Direct Shipper Permittees will also need to register as a “distributor,” as they make direct sales to consumers and so will need to collect and remit the CRV.

Registration as either a manufacturer or a distributor is available online or on a paper form available on CalRecycle’s website, along with links to lots of other useful information for suppliers subject to the bottle bill.

A word of caution on the registration form: when asked to provide the date when they began sales or transfers into California, wineries and distilleries should list January 1, 2024, as that is the date when they will be subject to the bottle bill, and not whatever date in the past that they actually opened to business in the state.

Getting ahead of registration is highly recommended as CalRecycle expects to be very busy this fall and winter processing all of the new applications. So, save yourself some stress over the holidays and don’t scramble to become compliant with the new bottle bill provisions at the last minute.

Take Action

Learn more about how Sovos ShipCompliant Direct can help you wrangle the latest DtC compliance requirements.

Sign up for Email Updates

Stay up to date with the latest tax and compliance updates that may impact your business.

Author

Alex Koral

Alex Koral is Senior Regulatory Counsel for Sovos ShipCompliant in the company’s Boulder, Colorado office. He actively researches beverage alcohol regulations and market developments to inform development of Sovos’ ShipCompliant product and help educate the industry on compliance issues. Alex has been in the beverage alcohol arena since 2015, after receiving his J.D. from the University of Colorado Law School.
Share this post

alcohol deliveries
North America ShipCompliant
December 20, 2024
What if No One is Home to Sign for an Alcohol Delivery?

This blog was last updated on December 20, 2024 When no one is home to sign for an alcohol delivery, it becomes more than just a minor hiccup for direct-to-consumer (DtC) alcohol shippers. It’s a domino effect that transforms a perfectly curated product into a customer’s disappointment before it’s ever opened. This becomes an even […]

taxation of motor insurance policies france
North America VAT & Fiscal Reporting
December 18, 2024
Taxation of Motor Insurance Policies: France

This blog was last updated on December 18, 2024 France is one of the most challenging countries in Europe when it comes to the premium tax treatment of motor insurance policies. This is mainly due to the variety of taxes and charges that can apply and the differing treatment of different vehicle types. This blog […]

california bottle bill compliance
North America ShipCompliant
December 13, 2024
California Bottle Bill: Compliance Updates for Wine and Spirits

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 […]

unclaimed property compliance for wineries
North America ShipCompliant
December 12, 2024
Unclaimed Property Compliance: What Wineries and Wine Clubs Need to Know

This blog was last updated on December 12, 2024 Although hard to believe, unclaimed property obligations impact ALL industries, including wineries and other wine clubs. While most companies typically only associate unclaimed property with outstanding checks, including accounts payable and payroll, there are other exposures for wineries and wine clubs to consider. Understanding these risks […]

retail delivery fees for alcohol shipping
North America ShipCompliant
December 5, 2024
Navigating Retail Delivery Fees: A Guide for DtC Alcohol Sellers

This blog was last updated on December 5, 2024 Direct-to-consumer (DtC) alcohol shippers are no strangers to navigating a complex regulatory landscape. However, recently, a new challenge has emerged—the rise of retail delivery fees. From excise taxes to shipping restrictions, the industry has long dealt with a maze of state-specific rules that require careful attention […]