US Bottle Deposit Laws for Imported Alcohol-Free Drinks

Ten US states run bottle deposit programs as of September 2026: California, Connecticut, Hawaii, Iowa, Maine, Massachusetts, Michigan, New York, Oregon and Vermont. An alcohol-free drink sold in any of them needs that state's refund mark on every covered container, and a business in your US supply chain has to register, report and pay the deposits. For alcohol-free wine, California is the state to plan around: its program has covered dealcoholized wine since January 2024, and the CRV label is now mandatory on those bottles.

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Key Takeaways

• Ten states, ten rulebooks. Deposits run from 5¢ to 15¢ on most containers, and each state sets its own label wording and registration.
• California covers dealcoholized wine. A 750 ml alcohol-free wine carries 10¢ CRV, and new stock has needed the CRV message since 1 July 2026.
• Coverage turns on the drink. California, Connecticut, Hawaii, Maine and Oregon reach most non-alcoholic drinks; the other five center on beer and carbonated drinks.
• In California, the importer holds the paperwork. State law treats whoever imports filled containers for sale in the state as manufacturer and distributor.
• One label can carry several states. Hawaii and Vermont law, and New York's regulations, expressly allow other states' names in the refund mark.

Which states have bottle deposit laws in 2026?

Connecticut's DEEP describes Connecticut as one of 10 bottle bill states, and its FAQ names them. Deposit, label wording and registration differ by state.

Several of the ten rewrote their rules in 2025 and 2026:

• California's AB 720 (Statutes of 2025, chapter 562), signed 10 October 2025, set 1 July 2026 as the labeling deadline for containers added in 2024, exempted stock filled and labeled before 1 July 2025, and allowed the message to be etched (PRC 14561).
• Vermont Act 158 of 2026, signed 17 June 2026, moves the state to producer responsibility. Most of it took effect on 1 July 2026. From 1 July 2027 every covered container needs a UPC and barcode, and no deposit initiator may sell without joining a producer responsibility organization approved by the Secretary of Natural Resources.
• Maine moved label registration from the state to its commingling cooperative on 15 July 2026 (38 MRSA §3105).
• Hawaii Act 158 of 2026, signed 25 June 2026, exempts distributors of fewer than five million containers a year from independent audits. The 1¢ container fee stays until 31 August 2027 (HRS 342G-102).
• Michigan Treasury has required all bottle deposit reports to be filed online since 1 January 2026 (Treasury).
• New York's bill S2351, which would raise the deposit to 10¢ and add liquor, cider, teas, juices and sports drinks, was re-referred to committee on 7 January 2026 and was still there in September 2026. Massachusetts law still sets the deposit at 5¢.

Is an alcohol-free drink covered?

Each state covers named categories. Oregon (ORS 471.001), Maine (28-A MRSA §2) and Iowa (Iowa Code 123.3) define wine by alcohol content, so a dealcoholized wine below 0.5% ABV falls outside their wine category and is covered, or not, as a non-alcoholic drink. California and Oregon name it as covered; Connecticut excludes it. For how the three alcohol-free categories differ in US law generally, see dealcoholized wine vs NA spirits vs NA beer.

"In" means the statute or agency brings the category in, by name or through a catch-all. "Out" means the state excludes it or it sits outside every listed category. "Check" means the texts leave it open.

The sources behind the table:

• California's law covers "wine, or wine from which alcohol has been removed" (PRC 14504), and CalRecycle's list of covered drinks places kombucha under tea.
• Connecticut's statute leaves out any product that contains wine or spirits and names kombucha, juice and plant water (CGS 22a-243); DEEP's list of covered beverages applies that exclusion to wines and spirits labeled non-alcoholic.
• Hawaii covers tea and coffee drinks and "all nonalcoholic drinks in liquid form" up to 68 fl oz (HRS 342G-101), which brings in kombucha. The statute does not define nonalcoholic, and DOH lists wine and spirits as out without addressing alcohol-free versions (DOH), so those two stay open.
• Iowa covers wine, liquor, beer, mineral water, soda water and similar carbonated soft drinks (455C.1); its beer definition starts above 0.5% ABV and its wine definition above 6.25% (123.3).
• Maine covers all non-alcoholic drinks, carbonated or still (§3102). The 15¢ rate is for wine and spirits, which Maine's deposit law defines by reference to the liquor code, where both mean drinks above 0.5% ABV (28-A §2). An alcohol-free wine or spirit under 0.5% therefore falls under the general 5¢ minimum (§3103).
• Massachusetts covers carbonated soft drinks, mineral water and beer, and excludes fruit juice and wine (§321).
• Michigan covers beer and other malt drinks "of whatever alcoholic content" and non-alcoholic carbonated drinks (445.571). Treasury treats kombucha as a non-alcoholic carbonated drink and reads non-alcoholic by the federal under-0.5% test (Treasury notice, 11 December 2019, revised 27 March 2020). That points toward coverage for sparkling alcohol-free wines and spirits too, but no Michigan text names them.
• New York covers carbonated soft drinks, unsweetened water, beer and other malt beverages, and wine coolers (ECL 27-1003). DEC lists still juice, still tea, wine and spirits as not covered, and carbonated tea as covered (DEC).
• Oregon covers water, malt drinks, carbonated soft drinks, kombucha and hard seltzer up to 3 liters, and almost any other drink from 4 fl oz to 1.5 liters except distilled liquor, wine outside a can and a few named products (ORS 459A.702). Oregon defines wine and distilled liquor as drinks of 0.5% ABV or more (ORS 471.001), so alcohol-free wines and spirits fall under that catch-all. OLCC lists non-alcohol wine, juice and kombucha as redeemable (OLCC) and excludes distilled spirits (OLCC).
• Vermont covers malt drinks, mixed wine drinks, mineral water, soda water, carbonated soft drinks and liquor (10 V.S.A. §1521, as amended by Vermont Act 158), and ANR lists non-carbonated non-alcoholic drinks and wine as not covered (ANR). Vermont's liquor code requires at least 1% alcohol for vinous beverages and more than 1% for spirits (7 V.S.A. §2), so an alcohol-free wine or spirit fits only if it is sparkling, as a carbonated soft drink.

What must go on the label?

California. One of the five messages must be etched, embossed, printed or securely affixed on every covered container (PRC 14561, as amended by AB 720). Bottles filled and labeled before 1 July 2025 stay exempt; later stock without the message needs it added, and the statute allows a securely affixed label. CalRecycle reviews label artwork on request and prefers die-line proofs at 300 ppi (CalRecycle).

Michigan. The container must show its refund value and the state name (445.572), and the deposit is at least 10¢ (445.571). Michigan's special reverse-vending mark, which must be unique to Michigan or shared only with states that have similar laws, applies to a brand selling at least 500,000 cases a year in 12 oz cans or bottles or 20 oz plastic bottles, or to a smaller brand over-redeemed by more than 600,000 containers (445.572a). Below those volumes, the refund value and state name, as in MI 10¢, meet the statute.

Oregon. OR 10¢, with no size, font or position rule; the statute requires only that the refund value be shown (ORS 459A.720). UPCs are optional, though containers missing from the statewide UPC system are hand counted (OLCC, April 2026).

UPC registration. Iowa has required UPC registration for alcoholic and non-alcoholic containers since 15 November 2023 (Iowa Code 455C.5, Iowa Revenue). Connecticut has required a UPC and barcode on every deposit container since 1 January 2024, and the deposit initiator must send the codes to reverse-vending operators at least 30 days before launch (CGS 22a-244). New York deposit initiators report every container type, with its UPC, to DEC (ECL 27-1012). Maine's label registration carries the UPC and is renewed each year and whenever the UPC, size, material or glass color changes (§3105).

The federal label comes first; the FDA labeling checklist for imported beverages covers the panel the deposit mark sits beside.

Can one label cover several states?

Yes, in most cases. Vermont law says the mark may include "names or abbreviations of other states with deposit legislation comparable" (10 V.S.A. §1524, as amended by Vermont Act 158), Hawaii's statute says the same (HRS 342G-112), and New York's regulations allow it too (6 NYCRR 367.8).

A workable format groups the states by value. A sparkling alcohol-free drink in a 330 ml can falls in every state's carbonated category, so its block could read CA CASH REFUND, then CT MI OR 10¢, then HI IA MA ME NY VT 5¢. For New York the refund value on a can must also appear on the top. A still 750 ml dealcoholized wine needs a different block, because Connecticut and Vermont exclude it. List only states where that SKU is covered.

Design to the strictest rules: at least 1/8 inch (New York, Hawaii, Vermont), at least 8-point (Massachusetts), on the side or top, never only on the bottom, and on the top of cans sold in New York.

Who registers, reports and pays?

New York, Connecticut and Vermont put the duty on the deposit initiator, the first business to collect the deposit on a container sold in the state (ECL 27-1003, CGS 22a-243, 10 V.S.A. §1530; see also NY Tax and CT DEEP). New York counts a business that imports filled containers into the United States as a bottler, and so as a deposit initiator (ECL 27-1003); Maine counts the importer of a drink made abroad by a company with no US presence as the manufacturer (38 MRSA §3102). California defines the beverage manufacturer to include anyone who "imports filled beverage containers" for sale (PRC 14506) and the distributor to include anyone importing for sale to dealers or consumers (PRC 14511).

Handling fees paid to stores and redemption centers add to the cost: 3.5¢ in New York (ECL 27-1007), 3¢ in Iowa (455C.2), 3.5¢ for soft drinks and still drinks in Connecticut (CGS 22a-245), at least 6¢ in Maine (§3106), and 4.5¢ or 5¢ in Vermont from 1 July 2026 (Vermont Act 158, ANR). Build them into your landed cost and margin model.

Do not assume your importer of record handles deposit registration. Agree who holds each state in writing; the trade-offs are in whether you need a US importer of record.

Do deposits apply to direct-to-consumer shipments?

In California, yes. CalRecycle says CRV must be reported and paid on internet sales and added to the invoice whenever CRV beverages ship to a California address (notice, 6 January 2021); the statute behind it counts anyone importing drinks for sale to consumers in the state as a distributor (PRC 14511). Hawaii law treats anyone who imports and sells filled containers to a dealer or consumer as a deposit beverage distributor (HRS 342G-101), and Hawaii Act 158 of 2026 adds a matching definition of "distribute". Maine applies its deposit to every container "sold or offered for sale to a consumer in this State" (§3103).

For the other seven states, confirm the position with the agency before switching on shipping. The wider DTC picture is in selling non-alcoholic drinks direct to consumers.

A launch sequence

1. Map every SKU to the states you will sell in, using the coverage table, and put the Check cells to the agency in writing.
2. Name the registrant in each state: importer of record, distributor or your US entity.
3. Register before the first sale. California, Hawaii, New York and Vermont require it (14 CCR 2231, HRS 342G-103, ECL 27-1012, 10 V.S.A. §1528).
4. Add the grouped deposit block to the US label and send the artwork to CalRecycle before printing.
5. Price the deposit and fees. The deposit rides on top of the shelf price; processing and handling fees come out of margin.
6. Diarise the reporting: monthly in California, Hawaii and Massachusetts, quarterly in Connecticut, New York and Vermont, annually in Michigan. Small payers in California and Hawaii can file less often.

Deposit registration sits beside FDA registration, labeling and importer-of-record duties in the work Avenor runs for European brands entering the US.

Sources

Laws and regulations:

1. Cal. Pub. Res. Code § 14504, definition of beverage: leginfo.legislature.ca.gov; Cal. Pub. Res. Code § 14506, beverage manufacturer: leginfo.legislature.ca.gov; Cal. Pub. Res. Code § 14511, distributor: leginfo.legislature.ca.gov; Cal. Pub. Res. Code § 14550, monthly distributor reports: leginfo.legislature.ca.gov; Cal. Pub. Res. Code § 14560, redemption payment and refund value: leginfo.legislature.ca.gov; Cal. Pub. Res. Code § 14561, CRV labeling, as amended by Stats. 2025, ch. 562: leginfo.legislature.ca.gov; Cal. Pub. Res. Code § 14574, distributor payments and administrative fee: leginfo.legislature.ca.gov; Cal. Pub. Res. Code § 14575, processing fees: leginfo.legislature.ca.gov
2. California AB 720 (2025), Stats. 2025, ch. 562, beverages and container labeling, chaptered 10 October 2025: leginfo.legislature.ca.gov
3. Cal. Code Regs. tit. 14, § 2231, beverage manufacturer registration: govt.westlaw.com; Cal. Code Regs. tit. 14, § 2301, distributor registration: govt.westlaw.com
4. Conn. Gen. Stat. § 22a-243, definitions: cga.ct.gov; Conn. Gen. Stat. § 22a-244, refund value, labeling and UPC: cga.ct.gov; Conn. Gen. Stat. § 22a-245, redemption and handling fees: cga.ct.gov; Conn. Gen. Stat. § 22a-245a, deposit initiator special account and reports: cga.ct.gov; Conn. Gen. Stat. § 22a-245b, small manufacturer exemption: cga.ct.gov
5. Haw. Rev. Stat. § 342G-101, definitions: capitol.hawaii.gov; Haw. Rev. Stat. § 342G-102, deposit beverage container fee: capitol.hawaii.gov; Haw. Rev. Stat. § 342G-103, distributor registration: capitol.hawaii.gov; Haw. Rev. Stat. § 342G-110, deposits and refund value: capitol.hawaii.gov; Haw. Rev. Stat. § 342G-111, distributor reports and payments: capitol.hawaii.gov; Haw. Rev. Stat. § 342G-112, container labeling: capitol.hawaii.gov
6. Hawaii Act 158 (2026), S.B. 3138, independent audits of deposit beverage distributors, signed 25 June 2026: health.hawaii.gov
7. Iowa Code § 455C.1, definitions: legis.iowa.gov; Iowa Code § 455C.2, refund values and handling fees: legis.iowa.gov; Iowa Code § 455C.5, refund value on the container and UPC registration: legis.iowa.gov; Iowa Code § 455C.18, unclaimed refund value: legis.iowa.gov
8. Iowa Code § 123.3, alcoholic beverage definitions: legis.iowa.gov
9. 38 M.R.S. § 3102, definitions: legislature.maine.gov; 38 M.R.S. § 3103, refund value: legislature.maine.gov; 38 M.R.S. § 3105, labels and label registration: legislature.maine.gov; 38 M.R.S. § 3106, handling costs: legislature.maine.gov; 38 M.R.S. § 3107, commingling: legislature.maine.gov
10. 28-A M.R.S. § 2, liquor, spirits and wine definitions: legislature.maine.gov
11. Mass. Gen. Laws ch. 94, § 321, definitions: malegislature.gov; Mass. Gen. Laws ch. 94, § 322, refund value: malegislature.gov; Mass. Gen. Laws ch. 94, § 323B, monthly reports: malegislature.gov; Mass. Gen. Laws ch. 94, § 323D, abandoned deposits: malegislature.gov; Mass. Gen. Laws ch. 94, § 325, refund value on the container: malegislature.gov
12. Mich. Comp. Laws § 445.571, definitions: legislature.mi.gov; Mich. Comp. Laws § 445.572, returns and labeling: legislature.mi.gov; Mich. Comp. Laws § 445.572a, designated containers for reverse vending: legislature.mi.gov; Mich. Comp. Laws § 445.573a, annual deposit report: legislature.mi.gov; Mich. Comp. Laws § 445.573b, unclaimed deposits: legislature.mi.gov
13. N.Y. Envtl. Conserv. Law § 27-1003, definitions: nysenate.gov; N.Y. Envtl. Conserv. Law § 27-1005, refund value: nysenate.gov; N.Y. Envtl. Conserv. Law § 27-1007, acceptance and handling fee: nysenate.gov; N.Y. Envtl. Conserv. Law § 27-1011, container labeling: nysenate.gov; N.Y. Envtl. Conserv. Law § 27-1012, refund value account, registration and reports: nysenate.gov
14. N.Y. Comp. Codes R. & Regs. tit. 6, § 367.8, beverage container requirements: govt.westlaw.com
15. New York Senate Bill S2351 (2025-2026 session), expansion of the bottle bill: nysenate.gov
16. Or. Rev. Stat. §§ 459A.702, 459A.705, 459A.718, 459A.720 and 459A.733, beverage containers (chapter 459A): oregonlegislature.gov
17. Or. Rev. Stat. § 471.001, alcoholic beverage definitions (chapter 471): oregonlegislature.gov
18. 10 V.S.A. § 1528, beverage registration: legislature.vermont.gov; 10 V.S.A. § 1530, abandoned beverage container deposits: legislature.vermont.gov
19. Vermont Act 158 (2026), H.915, amending 10 V.S.A. chapter 53 (including §§ 1521, 1522, 1524 and 1531), signed 17 June 2026: legislature.vermont.gov
20. 7 V.S.A. § 2, alcoholic beverage definitions: legislature.vermont.gov

Agency guidance and notices:

21. CalRecycle, Beverage Container Labeling Requirements: calrecycle.ca.gov; CalRecycle, Beverage Distributors and Manufacturers: calrecycle.ca.gov; CalRecycle, Beverages subject to California Refund Value (revised December 2023): calrecycle.ca.gov; CalRecycle, 2026 Processing Fees for Beverage Manufacturers, notice of 15 December 2025: calrecycle.ca.gov; CalRecycle, Important Notice on processing fees, internet sales and rulemaking, 6 January 2021: calrecycle.ca.gov
22. Connecticut DEEP, Connecticut Bottle Bill: portal.ct.gov; Connecticut DEEP, Bottle Bill Frequently Asked Questions: portal.ct.gov; Connecticut DEEP, Updated List of Covered Beverages as of July 1, 2025: portal.ct.gov
23. Hawaii Department of Health, FAQ Labeling Deposit Containers: health.hawaii.gov; Hawaii Department of Health, FAQ What's In? What's Out? (October 2022): health.hawaii.gov; Hawaii Department of Health, Distributor Registration Form (revised August 2023): health.hawaii.gov; Hawaii Department of Health, notice that the container fee remains 1 cent through 31 August 2027: health.hawaii.gov
24. Iowa Department of Revenue, Beer Distributor Reimbursement and UPC Upload Processes Under the Amended Bottle Bill: revenue.iowa.gov
25. Maine DEP, Maine's Beverage Container Redemption Program (Bottle Bill): maine.gov
26. Michigan Department of Treasury, Bottle Deposit: michigan.gov; Michigan Department of Treasury, Bottle Deposit: Distributors and Manufacturers: michigan.gov; Michigan Department of Treasury, Treatment of Kombucha Products Under Michigan's Bottle Deposit Law, 11 December 2019, revised 27 March 2020: michigan.gov
27. New York DEC, New York's Bottle Bill: dec.ny.gov
28. New York Department of Taxation and Finance, Beverage container deposits: tax.ny.gov
29. Oregon Liquor and Cannabis Commission, Bottle Bill: Redeemable Beverages: oregon.gov; Oregon Liquor and Cannabis Commission, Bottle Bill: Non-Redeemable Beverages: oregon.gov; Oregon Liquor and Cannabis Commission, Bottle Bill Retailer Guidelines (April 2026): oregon.gov; Oregon Liquor and Cannabis Commission, Bottle Bill Update: Distributor Requirements (revised September 2022): oregon.gov
30. Vermont Agency of Natural Resources, Vermont's Bottle Bill (timeline updated 4 September 2026): dec.vermont.gov; Vermont Agency of Natural Resources, Bottle Bill Fact Sheet: Manufacturers (September 2023): dec.vermont.gov

Other sources:

None. Every claim above rests on a statute, regulation or agency publication.

All sources accessed September 2026.

Summarized from state statutes and guidance from CalRecycle, Connecticut DEEP, Hawaii DOH, the Iowa Department of Revenue, Maine DEP, Michigan Treasury, NY DEC and the NY Tax Department, OLCC and Vermont ANR, as of September 2026. This is not legal advice; confirm each SKU's coverage with the state agency before printing labels.