Amendments to California’s bottle bill became law October 13, 2023. The new legislation (SB 353) made three important changes to the requirements for recycling wine and spirits containers in California that industry members need to know about.

The first and most important change is that wine and spirits containers filled and labeled before January 1, 2024 are now permanently exempt from deposit labeling requirements. The earlier legislation (SB 1013), which added wine and spirits containers to California’s recycling program starting next year, required mandatory deposit (CRV) labeling of all wine and spirits containers sold at retail after June 30, 2025.

That labeling requirement was a big headache for the wine industry, since it is common practice to age wine after bottling for extended periods of time. Participants at all levels of the industry would have been impacted by the difficulty of adding newly required statements to wine that had been bottled and labeled in the past. Much of this older wine is currently waiting for sale or importation, or is already in distribution. SB 353 cured the headache: Recycling fees will still be collected starting in January, but no label changes are required on wine and spirits containers bottled and labeled before January 1, 2024. 

Second, the bill also exempts all alcoholic beverages offered or sold to consumers for onsite consumption at a wine, beer, or spirits tasting room. This change officially relieves California manufacturers from collecting and remitting redemption fees on containers used for tasting. Bottles sold in tasting rooms to consumers are still subject to the CRV fees.

Third, the bill also amends the definition of “manufacturer.” Under the previous definition, the manufacturer category included importers, out-of-state direct shippers, and any companies that fill redeemable containers (“bottlers”) for sale in California. This definition fits poorly on the alcohol beverage industry: It leaves out alcohol beverage producers, and makes mobile bottling services and third-party bottlers responsible for processing fees instead. The new definition corrects this misfit by removing bottlers of alcohol beverages and adding all ABC-licensed manufacturers that sell their products to California distributors, retailers, or consumers—regardless of who else fills containers on their behalf.

The following pages on CalRecycle’s website have been updated to reflect the most recent changes:

https://calrecycle.ca.gov/BevContainer/BevDistMan/

https://calrecycle.ca.gov/BevContainer/BevDistMan/Labeling/

Reminder: If California’s recycling requirements apply to you and you haven’t registered yet, do it now! https://calrecycle.ca.gov/BevContainer/BevDistMan/Registration/

For a demonstration of The Digest, view the video, or contact us to schedule a live screen-share demo. Visit our website or give us a call: 800-400-1353.