Here’s a timely reminder about the new California recycling requirements going into effect January 1, 2024.

Registration with CalRecycle. If you haven’t already done so, it’s time to register with CalRecycle as a beverage manufacturer and/or beverage distributor, and make any changes to your POS and accounting systems needed to keep track of the fees that are your responsibility (described below). You also need to make sure that your POS system calculates the CA sales tax on the total retail price of wine sold, including the CRV fee.

CRV fees. If you sell wine or spirits to California consumers and/or retailers, you are considered a “beverage distributor” under CA’s recycling law. Beginning January 1 you must collect CRV fees on all bottle sales to California customers. CRV fees are $0.05/container for containers under 24 fluid ounces, $0.10/container for containers 24 fluid ounces or more, and $0.25 for bladders and boxes of any size. You will report and pay those fees to CalRecycle every month, beginning February 28, 2024.

Processing fees. If you’re a California producer or importer of wine or spirits, a brand owner that has assumed responsibility for the processing fees on wine or spirits produced or bottled on your behalf, or an out-of-state direct shipper selling to CA consumers, you are considered a “beverage manufacturer” under CA’s recycling law. You will owe processing fees on all containers sold in California beginning January 1. Processing fees are set each year for each type of container. The 2024 processing fee for glass is $0.00576/container. A chart showing the fees for all types of containers is available here: https://www2.calrecycle.ca.gov/Docs/Web/126525. You must report and pay processing fees to CalRecycle every month, beginning March 10, 2024.

Reporting. You need to receive your reporting account numbers from CalRecycle before you can begin reporting. Since the agency is onboarding thousands of new companies into their system, they do not expect to finish approving all the registration applications before the reporting due dates. However, even if you have not yet received your account numbers, you must still begin collecting and tracking the fees your company is responsible for beginning January 1, and submit your first reports once your registration is complete.

You can get more information about CalRecycle requirements from their website, https://calrecycle.ca.gov/BevContainer/BevDistman/, or contact the Registration Unit at 916-323-1835 or reg.crvlabeling@calrecycle.ca.gov.

SOVOS ShipCompliant is prepared to support the required reporting of CRV and processing fees. For more information about their services, please contact them directly.

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