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