California Redemption Value (CRV) is here for all wineries!
We're sure you're aware that new CRV regulations are in effect as of January 1, 2024. These regulations are affecting all wineries, not just California wineries.
If you are a winery in any state and you sell direct-to-consumer (DTC) into California, these changes apply to you.
Here's a rundown of the changes:
CRV Charges: Wine and distilled spirits products are now included in the California Beverage Container Recycling Program (BCRP). This means that a CRV ranging from $0.05 to $0.25 will be charged on these beverage containers. The specific CRV amount depends on the type and size of the container: 5 cents for containers less than 24 ounces, 10 cents for glass, aluminum, plastic, bimetal pouches, boxes, and cartons, and 25 cents for bag-in-box and other multi-layer pouches. These fees are collected at the point of sale and then remitted to CalRecycle, similar to how sales tax works.
Labeling Requirements: While the new CRV charges apply from January 1, 2024, beverage containers are not required to have CRV labeling until July 1, 2025. This provides a transition period for businesses to adjust to the new labeling requirements.
Reporting and Payment Obligations: Wineries and distilleries will be required to comply with the Bottle Bill’s CRV payment and reporting obligations. This includes registering with the state, submitting CRV payments, and updating labeling to reflect CRV amounts.
Direct-to-Consumer Sales: For direct-to-consumer (DTC) sales, wineries must pay the CRV directly to CalRecycle after assessing the CRV from the container purchasers.
Penalties for Non-Compliance: It's important to note that the maximum civil penalty for non-compliance with these regulations has increased significantly. This emphasizes the importance of adhering to these new rules to avoid potential fines.
Use Vinoshipper as your compliance partner
Here's the good news. If you are using Vinoshipper for sales into California, Vinoshipper will be taking care of the monthly payments for you. (This applies as well if you are using the OrderPort-Vinoshipper integration)
You can read more on Vinoshipper's strategy here.
You should have already received two forms from Vinoshipper to register with the state and authorize Vinoshipper to report and make payments on your behalf. If not, please reach out to Vinoshipper and make sure everything is on track.
What if I am not using Vinoshipper?
If you are not using Vinoshipper for your California sales, you will be responsible for filing monthly reports with CalRecycle.
Reports are due monthly for the first year, and if you are a small winery you will be moved to an annual filing schedule next year.
We will be reaching out to our CA clients and to our WA clients who do not use Vinoshipper for CA sales to make sure we have a plan in place to keep you in compliance!
What is OrderPort doing about the CRV charges?
OrderPort has added a "CA bottle fee" to their catalog that will automatically be applied to sales in California. Please take a moment to make sure you have your settings correct in OrderPort so that this process will work correctly.
For help with setting up OrderPort to account for CRV regulations, see their help article here.
If you have opinions . . .
We're lucky to work in the wine industry. We're not lucky that it is so highly regulated. If you want to take a look at some suggestions for how this bottle bill might be improved and make your voice heard, check out this article by Steve Harrison. His business has been actively involved in onboarding thousands of suppliers to comply with the regulations and has identified several gaps in both the process and understanding that are worth reading about.
Otherwise, if you have any questions from the accounting and reporting side of things, we’re always here to help. You can reach out to us any time by using our Get Started page.
Until next time.
