SB 1013 for Wineries: The 2026 CRV Compliance Guide

Why this matters now

July 1, 2026 is the forcing function. On that date, mandatory CRV indicia labeling enforcement begins for every non-exempt wine and spirits container sold in California. This deadline was originally July 1, 2025 under SB 1013, but AB 720 (signed October 10, 2025) pushed it back a year.

Here's the part most operators miss: the labeling deadline is the last obligation to arrive, not the first. SB 1013 (Atkins, Chapter 610) brought wine, distilled spirits, and box/bladder/pouch containers into California's Beverage Container Recycling Act effective January 1, 2024. Since that date, wineries have owed CRV deposits, owed processing fees, and owed monthly reports. If you've been selling to California consumers and haven't registered or filed, you're already behind — the labeling cliff just makes it visible.

AB 720 also did one generous thing: it moved the permanent labeling exemption cutoff from January 1, 2025 to July 1, 2025. Every bottle you filled and labeled before that date is permanently exempt from CRV labeling, regardless of when you sell it. That's roughly an extra six months of bottling that never needs an indicia. Documenting it correctly is the whole game.

Does SB 1013 actually apply to my winery?

Almost certainly yes, if you sell wine to California consumers.

The trigger is §14504, which expanded the definition of "beverage" to include wine, distilled spirits, and dealcoholized wine effective January 1, 2024. Before that date, wine sat entirely outside the program. After it, every winery and distillery selling into California became subject.

Two specifics worth flagging:

• Direct-to-consumer shippers are covered, including out-of-state. Under §14560 and §23661.3, the direct shipper permitholder is deemed the distributor for redemption-payment liability. Selling DTC to a California address means full CRV obligations — "we're not in California" is not a defense.
• Tasting rooms get a narrow break. A tasting room licensed under the ABC Act is not a "dealer" for CRV purposes (§14510), so it has no in-store redemption obligation for on-premises consumption. But off-premises sales — bottles taken home, club shipments billed from the tasting room — are still fully subject to CRV.

What changed, and what are the CRV fees by container type?

Two cost layers apply: the CRV deposit (statutory, set by SB 1013) and the processing fee (set by CalRecycle, updated annually).

CRV deposit amounts (per §14560, effective January 1, 2024):

• Glass / aluminum / PET, under 24 fl oz (e.g., 187mL, 375mL): $0.05
• Glass / aluminum / PET, 24 fl oz or more (incl. 750mL, 1L, 1.5L): $0.10
• Box / bladder / pouch (BIB), any volume: $0.25

The distributor retains 1.5% of remitted CRV as an administrative fee (§14573).

Processing fees are separate and are the winery's actual out-of-pocket cost. The 2026 glass rate is $0.00855 per container — the net rate after the §14575(j) surplus-funds reduction (the gross statutory fee is $0.00916), up from $0.00672 in 2025. CalRecycle sets these rates every January 1; the 2026 figures are in CalRecycle's December 15, 2025 Processing Fees Notice (Doc 137689).

A worked example: a 12,000-case winery sending 60% to California in 750mL glass ships roughly 86,400 bottles to CA. That's about $8,640/year in CRV passed through to CalRecycle, plus roughly $740/year in glass processing fees (86,400 × $0.00855), against about $130 retained as the admin fee — a net cash impact of around $600 a year. The deposits are mostly a pass-through. The paperwork is the real burden.

One change for BIB/pouch producers: the HDPE-equivalent processing fee that applied to wine/spirits box/bladder/pouch containers (under PRC §14575(k)) became inoperative on January 1, 2026. CalRecycle now sets container-specific 2026 rates — and they're dramatically higher: $0.32503 per bag-in-box, $0.02802 per multilayer pouch, and $0.02851 per paperboard carton (Doc 137689).

What do I have to file, and when?

If you're filing monthly, there are two recurring reports:

• Distributor Report (CRV remittance) — monthly: due the last day of the month following the sales month (e.g., April 30 for March sales).
• BM Report (processing fee) — monthly: due the 10th day of the second month following the sales month (e.g., March 10 for January sales).

Add the annual Plastic Content Report (due March 1, required of all beverage manufacturers even if exempt from the content standard) and, if you use a Pay-on-Behalf agent, the annual Pay-on-Behalf list due June 30. That's roughly 24–26 filings a year for a monthly filer.

The relief valve most operators don't know about: small producers can elect annual instead of monthly filing — but it's actually two separate elections against two separate thresholds, not one combined test:

• CRV redemption payments (distributors), PRC §14574(b): annual payment is allowed if your projected CRV for the calendar year is under $75,000 (at $0.10 per 750mL bottle, that's roughly 750,000 bottles to California, about 62,500 cases).
• Processing fees (manufacturers), PRC §14575(g)(3): annual payment is allowed if projected processing fees are under $10,000 — or under $15,000 if the refund value has been increased.

A winery is usually both a distributor and a manufacturer, so each election is judged on its own threshold: you might qualify for one, both, or neither. Both require a "pattern of operation in compliance" to CalRecycle's satisfaction, so approval is discretionary — you notify the department of intent by January 31 and the single annual payment is due February 1. For an eligible winery, this cuts filings from 24+ to roughly 3 a year.

To file electronically through CalRecycle's DORIIS portal, you also need a Portal Access Request (PAR), CalRecycle Form 752, mailed with an original signature.

What happens if I don't comply?

SB 1013 roughly doubled the civil penalties.

• General violation: up to $5,000 (each day of a continuing violation is a separate violation).
• Intentional or negligent violation: up to $10,000 (same per-day structure).

These apply to failure to register, failure to file, failure to remit, and — after July 1, 2026 — selling a non-exempt container without compliant CRV indicia. The unit matters: PRC §14591.1 sets these maximums "for each separate violation, or for continuing violations, for each day that violation occurs," and §14591.1(a)(3) states each day of a violation is a separate violation. So a continuing failure is per-day exposure, not a one-time cap — and it is not assessed per container. Late payments also accrue interest at the Pooled Money Investment Account (PMIA) rate under PRC §14593, which is variable, not a fixed percentage.

Two things sharpen the stakes:

• The ABC permit clause. For direct shippers, if CalRecycle determines you've failed to comply with redemption (§14560) or processing fees (§14575), it issues written notice; after a 30-day cure window, the Department of Alcoholic Beverage Control can prohibit your brand's sales in California (§23661.3(c)). For an out-of-state winery, that's a revenue event, not a fine.
• Personal liability. Under PRC §14591.2, the Department can reach officers, directors, and managing employees personally. For an owner-operated LLC, the owner is the registrant, officer, director, and managing employee all at once — the LLC veil does not fully protect.

One honest caveat: trade reporting indicates CalRecycle has effectively held off on late-registration penalties while it clears a registration backlog. That grace period is widely expected to close after the July 1, 2026 labeling deadline, likely with a compliance sweep. The penalties are largely theoretical right now. They become real after July 1, 2026.

How I'd handle this for a winery between 10,000 and 30,000 cases

Here's the order I'd work it.

First, fix registration. Confirm you're registered as both Beverage Manufacturer and Distributor — DTC shippers need both. You should hold two IDs per FEIN: a BM-prefixed number and a DS-prefixed number. If you only have one, you're mis-registered. Registration during the backlog has reportedly taken around four months, so this is the long pole.

Second, build the SKU and CRV catalog. I keep this in Airtable: one row per SKU with container material, size, the correct CRV amount, the processing-fee material rate, and a label-status flag. That flag is the heart of the July 1, 2026 problem — every SKU lands in one of four states:

• Exempt — filled and labeled before July 1, 2025 (permanently exempt from labeling).
• Grace — filled in the July 1, 2025 to July 1, 2026 window (current label without indicia is fine to sell).
• Compliant — CRV indicia present on the current label proof.
• Non-compliant — filled after July 1, 2025 without indicia; cannot be sold after July 1, 2026.

Third, defend the exempt inventory. The permanent exemption is worth real money on library wines, but only if you can prove the fill-and-label date to an auditor. For every batch claiming the exemption, I'd attach: bottling-date proof (production logs, TTB filings, bottling-line records), a photo of the pre-July-2025 label without indicia, an inventory ledger tying batch ID to bottle count to sales, and the custom-crush facility's records if someone else bottled it. FIFO depletion in most POS systems doesn't track batch IDs — that's the audit-loss pattern.

Fourth, classify channels correctly. Out-of-state and export sales are not CRV-eligible; I auto-flag those off ship-to address. But two surprises bite people: sample bottles and wine donations are NOT exempt for wine. A bottle shipped free to a sommelier or donated to a fundraiser carries the same CRV obligation as a sold bottle. What's free is the wine, not the deposit.

Fifth, run a filing checklist against the monthly (or, if you qualify, annual) calendar so nothing slips. Most 10,000–30,000-case Sonoma wineries qualify for the annual election — that's usually the single highest-leverage move.

If you'd rather not build all this from scratch, this is exactly what a CRV readiness sprint is for.

The labeling cliff is July 1, 2026, but the deposits and filings have been live since January 1, 2024 — so the right move is to get registered, catalog your SKUs, and document your pre-July-2025 exempt inventory before the grace period closes.

If you want a running start, grab the free CRV template — it's the SKU catalog, exemption tracker, and filing checklist in one place. And if you'd like help wiring it to your actual sales data, book a call or see services.