California’s Beverage Container Recycling Program Expands in 2025—Who’s Covered Now?
California’s Beverage Container Recycling Program (CRV), long a pillar of the state’s recycling infrastructure, is undergoing a seismic expansion. As of July 1, 2025, the program will include wine and distilled spirits, requiring new container labeling, distribution logistics, and redemption options. This regulatory milestone signals a broader policy trend: intoxicating beverages—regardless of base ingredient—may fall under deposit programs as recycling, sustainability, and consumer protection policies evolve in California.
This post examines whether California CRV THC beverages could join the deposit program after the 2025 expansion, explores key regulatory definitions, considers the possibility of non-alcoholic intoxicant beverages becoming subject to CRV, and charts a readiness plan for cannabis beverage brands.
Informational use only. Refer to official sources like CalRecycle for authoritative updates.
The 2025 CRV Expansion: What’s Changing for Wine & Spirits?
Key Timeline:
- Jan 1, 2024: Retailers began charging CRV deposits on wine and distilled spirits containers.
- July 1, 2025: All wine and spirits containers sold in California must bear approved CRV labeling (regardless of bottling date). Brands must also comply with all other CRV obligations.
What’s required?
- Container Labeling: All covered products must display a CRV redemption message (e.g., “CA Redemption Value,” “CA Cash Refund”).
- Distributor/Brand Registrations: Brands must register with CalRecycle as a beverage manufacturer and comply with reporting, fee remittance, and EPR (packaging responsibility) rules.
- Logistics & Retail Changes: Retailers must collect deposits at point of sale and help facilitate redemptions at approved locations.
Full details: CalRecycle Wine/Spirits CRV Guidance, Wine Institute FAQs
What Beverages Are Covered—And Where Are THC Drinks Positioned?
Statutory Definitions: Key to CRV Applicability
The CRV program is defined by the Beverage Container Recycling and Litter Reduction Act ("Bottle Bill"), codified at Cal. Public Resources Code § 14500 et seq. Which beverages are subject to CRV is set by law and interpreted by CalRecycle regulation.
As of 2025, covered beverages include:
- Beer, malt beverages
- Wine, wine coolers
- Distilled spirits
- Carbonated or non-carbonated water and soft drinks
- Most fruit and vegetable juices
What’s not covered?
- Milk, infant formula, medical food
- 100% non-beverage food products
- Until July 1, 2025: wine/spirits (for label mandate only)
- THC beverages and other non-alcoholic intoxicants—explicitly excluded (for now)
See CalRecycle’s full list of CRV-covered beverages
Could Non-Alcoholic Intoxicants Become CRV-Regulated?
THC beverages and hemp-derived intoxicant drinks (including "non-alcoholic spirits" with psychoactive cannabinoid additives) are not presently listed as covered beverages. But the expansion’s rationale—environmental stewardship and consumer consistency—suggests these categories are now in the regulatory crosshairs for future consideration.
Statutory Amendments Would Be Required:
- Current Law: There is no provision in the PRC or CalRecycle regulations for non-alcoholic, cannabinoid-based, or hemp-derived intoxicants as CRV-eligible beverages.
- Potential for Change: The Legislature could, by amending the definition of "beverage" or creating a new category, bring THC drinks under the program, paralleling the 2021 move to include wine/spirits. If public health, litter reduction, or market fairness arguments gain traction, expect pilot bills or regulatory proposals to surface as soon as 2026.
Key Takeaway: THC beverages are not covered by CRV as of 2025—but there is a credible pathway for inclusion if policymakers wish to act.
How Would CRV Apply to THC Beverages? Policy Pathway & Compliance Layers
If Included, THC Drink Brands Would Face:
- Container Label Review: Mandatory CRV indicia on every retail-facing unit (e.g., “CA Redemption Value – 5¢” or “CA Cash Refund”).
- Distributor/Manufacturer Obligations: Registration, reporting sales volumes, remitting CRV fees, and annual audits.
- Point-of-Sale Education: Retailers/dispensaries would need to collect deposits, inform consumers, and facilitate redemptions like any other beverage retailer.
- Redemption Logistics: Dispensaries and/or third-party locations would handle refunds, with CalRecycle authorization as a redemption center likely required.
Overlap with Packaging EPR (SB 54)
Starting in 2026, cannabis and all beverage brands face obligations under SB 54 (California’s sweeping Extended Producer Responsibility packaging law).
Read CannabisRegulations.ai’s guide to SB 54 and cannabis packaging obligations.
Key points of intersection:
- Double Compliance: If THC beverages are added to CRV, those brands would need to comply with both deposit/redemption and EPR reporting, fee payments, and recyclability mandates.
- Labeling: All claims of recyclability, compostability, or CRV status must be accurate and up-to-date to avoid penalties.
- Producer Registry: Both CRV and SB 54 will require detailed producer registration and data reporting, triggering possible audits.
What Defines a “Beverage Container” for CRV?
Per CalRecycle:
- Material types covered: Aluminum, glass, plastic (including bag-in-box, multi-layer pouches if for beverages after 2024–25 update), and bimetal.
- Exclusions: Containers not intended for single-use beverages, or formats not defined as ‘beverage’ by statute (such as pure food, supplements, or certain medicinal products).
Learn more via CalRecycle’s Beverage Types & Container FAQ
Readiness Plan: What Cannabis Beverage Brands Should Do If CRV Expansion Is Imminent
Cannabis, hemp, and intoxicant beverage manufacturers should prepare now in case a future bill brings THC drinks under CRV. Action steps:
1. Monitor Legislative and Regulatory Developments
2. Assess Packaging and Label Readiness
- Audit all beverage SKUs for container type, recyclability, and room for CRV indicia. Ensure design allows for required messaging, should CRV become mandatory.
- Coordinate label artwork reviews to accommodate potential quick pivots in regulatory language (e.g., 5¢/10¢ deposit, refund claims).
3. Prepare for Distributor/Manufacturer Registration
- Identify who (manufacturer, distributor, copacker) will be responsible for CalRecycle fee remittance and reporting.
- Consider options for centralized registration, especially for multi-state or cross-vertical beverage products.
4. Plan for Retail & Redemption Logistics
- Map potential redemption center partners in target retail geographies.
- Educate dispensary staff and point-of-sale teams on CRV deposit/refund mechanics to ensure compliance and smooth customer experience.
5. Coordinate EPR and CRV Data Flows
- Engage packaging compliance teams early—these data sets are overlapping but not identical.
- Review and harmonize reporting cycles for CRV and SB 54 packaging requirements by 2026.
Future Outlook: Will California CRV THC Beverages Become a Reality?
California’s 2025 bottle bill expansion has set a precedent: as intoxicating beverage formats evolve, so too will the regulatory and recycling regimes that govern them. Though THC beverages are not currently subject to CRV, they may be next in line if legislators seek equity between regulated intoxicant markets, environmental protection, and consumer clarity.
Takeaway for brands: Prepare packaging, compliance, and distribution systems today. Monitor Sacramento’s moves closely. Early preparation will minimize disruption and ensure you’re ready for compliance, consumer expectations, and retailer logistics should THC beverages be swept into CRV eligibility.
For the latest on cannabis packaging law, beverage compliance, and California regulatory strategy, rely on CannabisRegulations.ai—your trusted source for timely updates and actionable compliance insights.
