Suppliers of redeemable containers for sale in California must register with the California Department of Resources Recycling and Recovery (CalRecycle) by January 1, 2024 to participate in the program, and all suppliers are encouraged to register as soon as possible.

Registration can be done online or on paper. When you register, you must provide basic information on the business, and indicate whether the company is registering as a Beverage Manufacturer, a Beverage Distributor, or both. Before making that choice, you should be aware that the way CalRecycle defines the terms “manufacturer” and “distributor” is different than commonly used in the wine industry. You’ll need to understand their terminology in order to do the registration correctly:

• Beverage Manufacturers. Companies that fill redeemable containers for ultimate sale in California and companies that import redeemable containers into California must register as Beverage Manufacturers. Beverage Manufacturers are responsible for remitting the processing fees due for most types of containers.

• Beverage Distributors. Companies that sell redeemable containers to California retailers or directly to California consumers must register as Beverage Distributors. Included in this category are California wholesalers, California wineries selling direct to retailers and/or consumers, and out-of-state wineries shipping directly to customers in California. Beverage Distributors are responsible for collecting and remitting container redemption (CRV) fees.

CalRecycle considers the bottler—not the winery that owns or purchases the wine in the bottle—to be the Beverage Manufacturer that is responsible to pay the processing fees. In some cases, however, it is more appropriate for the bottler to transfer that responsibility to another company. Consider these common scenarios:

• If a winery bottles on-site with its own bottling line, it’s simple: The winery will register with CalRecycle as the Beverage Manufacturer and will pay the processing fees.
• If a winery contracts with a mobile bottling line or another winery to bottle its wine, the contract bottler is considered the “Beverage Manufacturer,” and is expected to pay the processing fees on wine they bottle for their client.
• If a winery bottles wine for another winery or brand owner, the bottling winery is the “Beverage Manufacturer,” and is expected to pay the processing fees on wine it bottles for its client.

It makes sense for the company that owns the wine and brand to pay the processing fees, because that winery can delay payment of the fees until the bottles are released into the California market, and pay only on those bottles that end up in California. Processing fees are not owed on wine bottled in California but sold to customers outside California.

CalRecycle has established a procedure that allows the reporting and payment of processing fees to be shifted from the bottler to another company. This can be done at the time of registration or later by submitting a written statement, signed by both companies, that the other company will pay processing fees on behalf of the bottler.

After registrations are received, representatives from CalRecycle’s Registration Unit will conduct phone interviews to make sure each company is properly registered. Then the agency will assign each company account numbers and a representative in CalRecycle’s Participant Management Unit to assist with reporting and other operational questions.

For more information, check out these links on CalRecycle’s website:

Registration information: https://calrecycle.ca.gov/bevcontainer/bevdistman/registration/
Online registration portal: https://www2.calrecycle.ca.gov/BevContainerDetermination/
CalRecycle Registration form: https://www2.calrecycle.ca.gov/Docs/Web/111495

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