Guidance for DTC Licensees for Complying with Maine Bottle Bill Law

DTC wine beverage containers are added into Maine’s bottle bill program effective July 1, 2025. To comply with the existing bottle bill as of July 1, 2025, California wineries that ship wine directly to Maine consumers should prepare to comply with the requirements listed below: 

Only one company is permitted to register product labels of the same brand and act as the Initiator of Deposit (IOD) (current Rule Chapter 426, section 6  and concept draft language.)

If a winery wishes to sell product labels of the same brand through both the DTC and Wholesale channels the winery must register as the IOD.

  • When there is a change to the initiator of deposit of a beverage, or when an initiator of deposit changes its contracted agent or its participation in a commingling agreement, the initiator of deposit will provide obligated dealers that redeem beverage containers, redemption centers and the Department with notice of any changes that affect container sorting or pickup requirements. If there is a change in the initiator of deposit, the original and new initiators of deposit will determine the date on which the new initiator of deposit will be responsible for pick- up. In no case will the effective date occur more than 35 calendar days from the date the new initiator of deposit takes over sales for the brand. (source – Concept Draft Language for Returnable Beverage Container Rule)

An IOD is responsible for:

  • initiating the deposit,
  • the pick-up of its beverage containers or its share of the comingled beverage containers from dealers and redemption centers,
  • facilitating the recycling or refill of the containers,
  • paying the obligated dealers and redemption centers the handling fees,
  • reimbursing obligated dealers and redemption centers for the deposits paid out on containers.

 *The obligations of the IOD may be fulfilled by the IOD directly, through the commingling group in which it is a member, or a third party. The IOD is the entity which is ultimately responsible for these obligations.*

IOD Registration and Compliance
Step 1: Sign up with a comingling cooperative/pick up agent.
  • All Initiators of Deposit for beverages in Maine are required by law to enter into a commingling agreement (3107. Commingling of beverage containers)
  • Listing of commingling groups in Maine.
  • Draft concept language requires commingling groups to provide “contact information” and “a description of how initiators of deposit can join the commingling group, including timeline and requirements to join, which must allow new initiators of deposit to join under the same terms and conditions of the original agreement”
Step 2: Apply to DEP for IOD License and Register wine container labels with DEP through the online portal.
  • 2017 DEP Bottle Bill Portal Instructions
    • If you have any questions about using or accessing the portal please contact Jaime Taylor at A.Taylor@maine.gov.
    • Note that BABLO brand label product registration is not a requirement for products sold through the DTC channel.  Only brand labels distributed through Maine wholesalers must be registered with BABLO.
  • The annual IOD license fee is
  • Required Beverage Container Data
    • Product name
    • category of Beverage, i.e., wine, wine cooler, spirits, beer, water, hard cider/hard juices, other;
    • the container material Type
    • if glass, the color;
    • UPC or EAN, unless the product is a Wine product that is not labeled with a UPC or EAN
    • the commingling group in which the product is included
    • not submitted with a previous year’s label registration, a copy or photograph of the beverage container label or a signed statement certifying that the beverage container being registered is marked with the deposit refund value in accordance with 38 M.R.S. §3103 and Section 8
  • Label Registration Fee
    • Prior to July 15, 2025, the department may charge a fee for registration and registration renewals. The current fee for wine container labels is $1.00 per product label.
    • Beginning July 15, 2025, registration must be on forms or in an electronic format provided by the commingling cooperative.
    • Beginning July 15, 2025, a commingling group shall ensure that all initiators of deposit participating in the commingling group provide to the cooperative accurate and up-to-date label registration information required by this subsection and that any updates to label registrations are provided to the cooperative at least 30 days prior to introduction for sale in the State. The cooperative shall ensure that accurate and up-to-date information regarding all label registrations is shared with entities using or administering reverse vending machine and account-based bulk processing programs and is made available on its publicly accessible website.
    • 3105. Labels; stamps; brand names

Step 3: CRV Labeling and Refund Value– The required refund value must be printed on the container or for wine and spirits products only the IOD shall ensure that a Department-approved sticker that clearly identifies the Initiator of Deposit and the deposit/refund value is affixed to the Product container.

Prior to the sale of a Wine or Spirit container to which a separate sticker stating the refund value is to be affixed, the Initiator of Deposit shall submit a sample of the sticker to the Department for approval. Approval will be based on the readability, suitability, and durability of the sticker.

  • Refund Value
    • A 15¢ refundable deposit on spirits and wine beverage containers greater than 50 milliliters
    • A 5¢ refundable deposit on wine and spirits containers of 50 milliliters or less.
    • 3103. Refund value
Step 4: Reimbursement of handling fee & costs (§3106(7))

The commingling group must charge the IOD for

  • the handling fee on its redeemed containers (The handling fee is at least 6¢ for containers picked up on or after September 1, 2023.)
  • the deposit on its containers
  • the share of administrative and pick up charges associated with the initiator of deposit’s share of the total beverage containers managed. The share of beverage containers belonging to each initiator of deposit can be based on sales data and/or return data. Fees should account for any extra cost associated with managing an initiator of deposit’s beverage containers that results from container design and composition.

Step 5: Collect CRV fee on DTC sales shipped into Maine. For sales shipped directly to a consumer, collect the 15¢ per container deposit fee on each bottle of wine shipped to a Maine address.

  • The definition of sale price does not include any charge, deposit, fee or premium imposed by a law of this state.
  • Note that wine packaged in containers less than 250ml may NOT be shipped DTC.
Step 6: Annual Reporting
  • Initiators of deposit must annually report the number of containers sold into the State by redemption value and beverage container material type and size.  Additional language is included if the manufacturer is reporting actual sales data, or it is estimating the number containers sold due to lack of actual data.

Maine Revenue Services Initiator of Deposit Tax

  • Maine DRS Repeal Notice Initiator of Deposit, effective 10/15/24
  • The last Initiator of Deposit return for initiators that are not in a commingling agreement will be for the September 2024 period, due October 20, 2024. Initiator of Deposit accounts will not be required to file any Initiator of Deposit returns for periods due after October 20, 2024

For more information visit the Maine Bottle Bill Compliance and Maine DTC web pages.

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