Starting July 1, 2025, wine bottles shipped DTC to Maine consumers will be covered by Maine’s recycling program. Previously, wine sold at wholesale has been subject to the recycling requirements, but wine shipped DTC has been exempt. To continue shipping DTC to Maine beyond July 1, wineries will need to comply with the requirements of that program. 

A law passed in 2023 required this change, but the implications for DTC shippers were uncertain. On June 4, 2025, the Maine Department of Environmental Protection (DEP) issued a memo explaining the program and its requirements for DTC shippers. We’ve summarized them briefly below.

In order to continue to ship DTC to Maine after July 1, wineries must become the responsible party for recycling requirements by registering as an Initiator of Deposit (IOD). To become an IOD, wineries need to obtain a license from the ME DEP. The annual fee for wineries producing no more than 50,000 gallons a year is $50. The annual fee for wineries producing more than 50,000 gallons is $500. 

In addition, wineries must join an existing “commingling group.”  Commingling groups are in-state organizations responsible for handling the bottles once a consumer redeems their deposit and puts the bottle into the recycling stream. The commingling group may charge fees for both membership and collection. 

As the IOD, DTC shippers will be responsible for labeling their bottles with the ME redemption value (15¢ for wine bottles), registering their labels with ME DEP, collecting the deposit from Maine purchasers, and reporting and remitting the deposits collected. 

Wineries that sell and ship both DTC and wholesale need to carefully consider the program requirements. Currently, the ME wholesaler is the IOD for wine shipped wholesale into Maine and handles all of the recycling program requirements (labeling, registration, membership in the commingling group, collection of deposits and reporting). However, the DEP system only allows a single IOD for each label; these responsibilities will shift to the winery after July 1 if it continues to sell in both channels. A winery shipping any label both DTC and wholesale will become responsible for meeting the recycling requirements for both its wholesale shipments and its DTC shipments of that label.

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