EPR for Wineries: Start Here
Oct 1, 2026 | 4 min read
EPR for Wineries: What Califonia’s SB 54 Means for You
Written by Jeanette Tan | Photo by Shutterstock.com
Wait, there’s a new compliance program?
It usually starts with a conversation. You’re pouring at an event or catching up with a neighboring winery, and someone mentions a new CalRecycle program for packaging. They’ve heard it’s a big deal. They’ve heard there’s registration, reporting, and fees.
Then comes the part that makes your stomach drop: the first deadlines have already passed.
You ask around, and nobody seems to know much more. Your accountant hasn’t mentioned it. Your distributor shrugs. And you’re already juggling TTB reports, ABC renewals, excise taxes, label approvals, and everything else that comes with running a small winery. One more compliance program feels like one too many.
If that’s where you are right now, take a breath. You’re in the right place.
In the next 10 minutes, you’ll learn:
• What this program actually is
• Whether it affects your winery (spoiler: it almost certainly does)
• What to do first
• Where to go next for help
“But my wine bottles are already covered by CRV”
This is the first thing most winery owners say, and it’s a reasonable thought. Since 2024, wine bottles in California carry CRV, the California Redemption Value. You’re already paying into one recycling program. Why would a second one apply?
Here’s the catch: the EPR Program isn’t just about the bottle.
In California, your glass wine bottles are excluded because they’re already part of the CRV program. But the rest of your packaging is not. Think about everything else that leaves your winery with a bottle: the capsule, the boxes, the dividers, the shipping boxes, the inserts in your wine club shipments.
And California isn’t the only state with an EPR Program. Several other states have them too, and in those states, the glass bottles themselves are included. If you ship to customers or sell through distributors outside California, your bottles may be covered there even though they’re excluded here.
What is EPR? The picnic lunch version
Imagine a restaurant that sells picnic lunches in disposable containers. Customers carry their lunches to the park, enjoy their food, and toss the packaging in the trash. Traditionally, the city pays to collect and dispose of all those containers.
But what if the restaurant that handed out those containers had to help pay for cleaning them up?
That’s the basic idea behind Extended Producer Responsibility, or EPR. The businesses that put packaging into the marketplace help pay for what happens to it afterward.
Who’s involved in California
• SB 54. California passed the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) in 2022. It authorized CalRecycle to write the regulations that make the program work.
• CalRecycle. The state agency that oversees the program.
• The PRO. Businesses can report directly to CalRecycle or through a Producer Responsibility Organization, or PRO. Smaller businesses like wineries will use the PRO.
• The Circular Action Alliance (the CAA). The CAA is the PRO for California. It’s also the PRO in Colorado, Maryland, Minnesota, Oregon, and Washington, so if you sell in several of those states, you’ll deal with the same organization. Maine runs its program differently.
• You, the producer. This is where many winery owners get tripped up.
Why you’re the “producer”
You might think, “I don’t make packaging. I buy it.” But in an EPR Program, the producer is generally the brand name on the product, not the company that manufactured the packaging. If your winery’s name is on the label, you’re the producer.
Does the EPR Program apply to my winery? A 4-question self-check
Answer yes or no:
Do you sell physical goods in a package?
Do you sell or distribute products in any of these states: California, Colorado, Maine, Maryland, Minnesota, Oregon, or Washington? (as of 2026)
Do you own the brand? (This doesn’t apply to retailers, distributors, or resellers.)
Do you have more than $1 million in California sales? (Other states have different thresholds.)
If you answered yes to all four, the rules likely apply to you in California.
If you answered yes to the first three but your California sales are under $1 million, don’t stop reading. You may qualify for the Small Producer Exemption, but it isn’t automatic. You must apply for it.
If you sell in other EPR states, check each state’s rules. Their thresholds are different, and their programs include the glass bottle.
Skipping the application doesn’t make you exempt.
What it looks like when you have the EPR Program handled
Fast forward a year. The annual report is due again, and this time it’s not a scramble.
You’ve set up a few simple internal procedures.
• You know what every piece of packaging on every SKU is made of and how much it weighs. You already had this information, but it was scattered in different Excel files. Now it’s saved in one place. Since you bought all the same materials as the previous year, you didn’t have to update it.
• Your sales records show which state every case shipped to.
• Your purchasing records show how many shipping boxes and dividers you bought.
• When the report is due, you pull the numbers from systems you already use and run them through a process that calculates the weight of each material sold or shipped to each state.
Notice what made the difference. It wasn’t a stack of new paperwork. It was a few tweaks to your system.
Today, EPR reporting feels overwhelming because the information is scattered across invoices, spec sheets, and memory. Next year, and the year after, it becomes routine because your packaging data, purchasing, and sales records are organized to answer the question before anyone asks it.
And when the fees are announced, you won’t be guessing. You’ll already have the numbers to see what the EPR Program adds to your overhead and plan for it in your budget and pricing.
Your EPR roadmap: 8 first steps
You don’t have to do everything at once. Work through these in order. Each step will link to a post or video in this series.
Confirm whether you’re a producer. Use the self-check above. If your brand is on the label and you sell in an EPR state, the answer is probably yes.
If you qualify, apply for the Small Producer Exemption. In California, this applies to wineries with less than $1 million in California sales. You must apply, and the exemption must be renewed every 2 years.
Register with the CAA for your home state. This is a one-time registration.
If you sell in other EPR states, register there too. Each state has its own rules and thresholds.
Document your packaging. For each primary packaging component (container, closure, capsule, label, and box), identify what it’s made of and how much it weighs. In California, also identify the weight of any plastic it contains. Do the same for your secondary and tertiary packaging, like boxes, dividers, and shipping materials.
Track secondary and tertiary packaging purchases. Create a simple procedure to record the quantity of boxes, dividers, and shipping materials you buy.
Make sure every sale records a “ship to” state. Review your sales procedures across every channel (tasting room, wine club, eCommerce, and wholesale) so you can report by state.
Build EPR fees into your budget and pricing. Once fees are known, add them to your overhead budget and factor them into your pricing.
Key California dates
The first round of California deadlines fell in mid-2026. If you missed them, you’re not alone. The best move now is to register with the CAA, or apply for the Small Producer Exemption if you qualify, and get your data in order.
| Requirement | Data year | Due |
|---|---|---|
| Submit 2026 Baseline Producer Report | 2023 | May 31, 2026 (accepted through June 1) |
| Submit 2026 Annual Supply Report | 2025 | May 31, 2026 |
| Submit 2026 Annual Source Reduction Report | 2025 | May 31, 2026 |
| Register with the CAA | n/a | June 1, 2026 |
| Submit Individual Source Reduction Plan | n/a | August 1, 2026 |
| Pay California Early Fees | 2025 | Within 45 days of the CAA's invoice (after filing the 2026 Annual Supply Report) |
Last updated: October 2026
The 30-second recap
• The EPR Program makes wineries help pay for the recycling and waste management costs of the packaging we put into the market.
• You report the total weight of our packaging, by material, for the products we sold into each participating state.
• You pay fees based on the type of packaging material, its weight, and each state’s rules.
Where to go next
Wherever you are, there’s a next step that fits.
• Want to stay in the loop? Join our EPR updates list for winery-specific news as the EPR Program develops. We’ll let you know when our EPR for Wineries – Course + Workbook and our EPR Analysis Service are available.
• Ready to start on your packaging? Download our free vendor email templates. They make it easy to ask your glass, closure, capsule, label, and box suppliers for the material and weight information you’ll need.
• Want to do it yourself, with a guide? Our EPR for Wineries – Course + Workbook (coming soon) walks you through every step on the roadmap above, from registration to building fees into your pricing. Join the EPR updates list to hear when it opens.
• Want help with the math? Send your completed workbook to our EPR Analysis Service (coming soon), and we’ll calculate the weights and plastic counts for your reports.
The EPR for Wineries series
This page is your home base. Each post below goes deeper on one part of the roadmap.
• Is Your Winery Exempt from California EPR? How to Tell If You’re a “Small Producer” — what counts toward the $1 million threshold and how to apply.
• EPR for Small Wineries: What Counts as Packaging — the packaging checklist, how to weigh it, and free vendor email templates.
• California EPR Reports for Wineries, Translated into Plain English — the four California reports and the acronyms, decoded.
• California EPR Penalties: What Happens If Your Winery Doesn’t File? — the penalties, the lawsuits, and what to do if you missed a deadline.
• How Much Will EPR Fees Cost Your Winery? — coming soon. [LINK]
About the author: Jeanette Tan is the founder of QB Winery Solutions. She has worked exclusively with small wineries for over 15 years and has taught at Sonoma State’s Wine Business Institute.
Disclaimer: QB Winery Solutions is not a law firm or regulatory compliance company. This information is intended to be educational and is not legal advice. EPR rules and deadlines are still changing; this post reflects what we know as of the "Posted" date above. Confirm material classifications, exemptions, and reporting obligations with your attorney, compliance professional, vendors, and the applicable state program.
