This blog has been updated with the latest information to help wineries stay compliant as new deadlines and details emerge. 

As of January 1, 2024, big changes have come to California’s Beverage Container Recycling Program—commonly known as the Bottle Bill. For the first time, wine and spirits are included under the law, which means new requirements for wineries that ship directly to consumers in California. 

With few exceptions, beverage manufacturers—including DTC wine shippers—must begin labeling containers with a California Redemption Value (CRV) message by July 1, 2025. Understanding what is required and how to stay compliant is essential to avoid penalties and ensure smooth fulfillment. 

In this post, we’ll break down what these updates mean for your winery, how they impact your shipments to California consumers, and what steps to take next. 

What You Need to Know:

• Wine products sold in (and shipped to) California will be subject to both processing fees and CRV  

• The CRV message is not mandatory on shipping boxes.  Only on each individual wine or distilled spirit (coolers included) beverage containers. 

• DTC wineries will be considered “distributors” and likely will also be considered “manufacturers”  

• The responsibility is on the manufacturing license (the winery) 

• Labels and/or containers can begin to show one of 5 different allowable CRV messages effective January 1, 2024, but the messages will not be mandatory until July 1, 2025 

• The CRV can be, but doesn’t have to be charged to consumers  

• The CRV can be, but doesn’t have to be listed separately on the consumer invoice  

• Adding the CRV fee to an approved label is considered an allowable revision with TTB   

• The CRV is subject to sales tax (the fee is taxable if the sale of the beverage is subject to sales tax)  

• WineDirect Fulfillment will work with our compliance partners to support the collection of the CRV  

Are Wineries Manufacturers, Distributors, or Both? 

The definitions of “manufacturer” and “distributor” within the BCRP are different than the definitions of the same terms under the California Department of Alcoholic Beverage Control (ABC) regulations. CalRecycle have previously clarified that Beverage Manufacturers are anyone who does any of the following:  

• Bottles, cans or fills beverage containers in California (including mobile bottling lines)  

• Imports beverages into California for sale to distributors, dealers, or consumers.  

• Holds a Certificate of Compliance with ABC (Beer/Malt only)  

• Is an out-of-state entity, holding a Wine Direct Shippers Permit with ABC  

Distributors are anyone who does any of the following:  

• Sells beverage containers to a dealer in California  

• Imports beverages from outside California for sale to dealers or consumers in the state  

• Is an out-of-state entity holding an ABC Wine Direct Shippers Permit  

• Is a beverage manufacturer or brand owner selling DTC in California  

So, both out-of-state wineries and in-state wineries now qualify as distributors for their DTC sales to California residents. Out-of-state DTC wineries are also manufacturers, and in-state wineries are also manufacturers for their DTC sales to California residents, unless they do not do their own bottling. However, wineries that use 3rd party bottlers will need to complete paperwork in coordination with their bottler to transfer the beverage manufacturer responsibilities back to the winery.  

Processing Fees and CRV Rates

Rates can be found here. The CRV can be but doesn’t have to be charged to the consumer. CRV fees, which are paid by distributors, are:  

• $.05 for bottles under 24 ounces (24 ounces is about 710 mL, so anything smaller than 750 is $.05)  

• $.10 for bottles 24 ounces and above  

• $.25 for all other package types (boxes, bladders, pouches)  

Processing fees, which are paid by manufacturers, are listed in the table here. The glass rate is currently $.00576.

Approved CRV Messages 

Wine and distilled spirits containers must be labeled by July 1, 2025 with one of the five CRV message options below:  

1. California Redemption Value  

2. CA Redemption Value  

3. California Cash Refund  

4. CA Cash Refund  

5. CA CRV  

The CRV message can be added before July 1, 2025. Adding one of these CRV messages would be considered an allowable revision by TTB (see #12 in the table on this page), so a new Certificate of Label Approval (COLA) would not be required if the only change to the label is adding the CRV message. 

Labeling Options

Navigating regulatory updates like California’s Bottle Bill can be daunting—but you don’t have to manage it alone. If your winery ships DTC to California, WineDirect Fulfillment is here to help you stay compliant. 

As part of our services, we can apply CRV-compliant labels directly to your bottles before they ship. Whether you're looking for a temporary labeling solution while you update your packaging or a long-term fix, we’ll work with you to find the right option for your business. For wines and distilled spirits, the font height used for temporary stickers CRV messages must be at least 3/16” or 1/8” in a contrasting color.  Stickers must be smudging proof and firmly adhered to the container. 

Labeling Project Rates 

WineDirect Fulfillment can provide preprinted “CA CRV” stickers that meet CalRecycle requirements, making it easy for you to stay compliant. From now until September 1, 2025, a special Summer Project fee of $0.10 per bottle will apply. To get started, contact your Account Manager to schedule your labeling. 

Additional resources: 

• Webinar on July 12th: Preparing for Upcoming DTC Wine Changes
• CalRecycle home page for Beverage Distributors & Manufacturers 
• CalRecycle May 10^th webinar for Wine and Spirits Industry
• CalRecycle Registration page 
• 2023 fees and redemption values 
• Helpful blog post from our friends at DP&F