Manufacturers and distributors of beverages covered by the Bottle Bill are responsible for paying the applicable fees. Thus, they must register with the California Department of Resources Recycling and Recovery (CalRecycle) as a manufacturer, a distributor, or both a manufacturer and a distributor.
The Bottle Bill actually imposes two separate fees. Businesses registered as a manufacturer are responsible for paying processing fees. Businesses registered as a distributor are responsible for paying the California Redemption Value, or CRV. California allows distributors to claim a 1.5% administrative fee discount.
What is a beverage manufacturer?
When it comes to responsibility for paying the processing fee, a beverage manufacturer is anyone who:
- Bottles, cans, or otherwise fills beverage containers in California with a beverage that’s not beer, wine, or distilled spirits; or
- Holds a manufacturing license with the California Department of Alcoholic Beverage Control (ABC) for beer, wine, or distilled spirits, regardless of who fills the container; or
- Imports beverages into California for sale to consumers, dealers, or distributors; or
- Holds a certificate of compliance for beer or malt beverages with the ABC; or
- Holds a wine direct shipper permit with the ABC.
In October 2023, California updated the definition of a “beverage manufacturer” for wine, beer, and spirits to better align with industry standards and clarify that the holder of the ABC manufacturing license is liable for the bottle processing fee even if a third party bottles or otherwise fills the beverage container — so long as the licensee sells the product. If a third-party bottler fills and sells a product, the manufacturer would be considered responsible for the processing fee.
Processing fees and payments are subject to change. Current and historical processing fees and payments are available at CalRecycle.
What is a beverage distributor?
With respect to the California Redemption Value (CRV) fee, a distributor is:
- Any person who engages in the sale or import of qualifying beverages in qualifying beverage containers to a dealer in the state; or
- Any manufacturer or importer who engages in sales to consumers or dealers in California; or
- The person or entity named on the direct shipper permit issued by the ABC.
In October 2023, California passed a law that exempts a beverage distributor from the requirement to pay a redemption payment (CRV) for a beverage container used solely to pour wine, beer, or distilled spirits at a licensed wine, beer, or distilled spirits tasing room. It also exempts licensed beer tasting rooms from the definition of a dealer. This change takes effect January 1, 2024.