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“Container Deposit” schemes are State regulations aimed at reducing waste and/or increasing return rates of used beverage containers. The legislation that creates these programs is often called a “Bottle Bill”.
While Bottle Bills are commonplace for soda cans and other beverage containers, distilled spirits have long enjoyed an exception to those regulations in most states. However, updated Bottle Bills which include distilled spirits are making their way through some large state legislatures.
What you might not know is that several states already require distilled spirits manufacturers to label their bottles with redemption values and participate in the deposit scheme. In some cases, the requirement only applies to “mixed spirits drinks” (like cocktails in a can). In others, it applies to all spirits/liquor.
Hawaii: 5¢ on “mixed spirits” containers
Iowa: 5¢ on “liquor” containers
Maine: 15¢ on “wine/liquor” containers
Michigan: 10¢ on “canned cocktail” containers
Vermont: 15¢ on “liquor” containers
Guam: 5¢ on “mixed spirits” containers
Of note is a recent Bottle Bill in California (SB 1013) which requires distilled spirits manufacturers to participate in the “CA Redemption Value” program. This was signed into law earlier in 2023, but takes effect beginning in 2024: DSPs in CA should register with CalRecycle ASAP because reporting and payment obligations begin on January 1, 2024. By 2025, all bottles must be labeled with their appropriate CRV.
Over in New York, the State Senate is considering SB S237B, which would add distilled spirits to the existing deposit scheme (and increase rates from 5c to 10c).
An old adage comes to mind: “As California Goes, so Goes the Nation”.
The trajectory is clear – Bottle Bills are coming for distilled spirits. Labeling changes will be part of complying with these changes. Luckily, TTB lists “Add, delete, or change bottle deposit information” as one of the “allowable revisions” for distilled spirits labels, meaning that a new COLA is not required if that is the only revision being made.
Reach out to FIVE x 5 Consulting if you have any questions. We can help you approach these regulatory requirements in a strategic manner to minimize costs and ensure compliance.
