A costly new mandate is taking shape in Washington, DC, and its impact will not stop at the District line.
The District of Columbia is considering implementing a pricey and structurally flawed beverage container deposit system, even as businesses and consumers confront extraordinary economic pressures. The proposal is not merely expensive; it is operationally unworkable and financially unsustainable.
The burden goes far beyond paying a 10-cent deposit on beverages sold in plastic, metal, and glass containers, with narrow exceptions. The District of Columbia would require businesses and individuals that bring beverages into DC for resale to finance and operate an expensive and complex system for collecting, transporting, sorting and processing used containers. These responsibilities require significant infrastructure investment before the program operations can start in a jurisdiction that must farm out all its materials processing because it lacks recycling facilities of its own. This extraordinary burden will be shouldered not just by DC business, but by many businesses operating beyond DC’s borders.
In short, your warehouse doesn’t have to be in Washington, D.C., for the District’s proposed bottle bill to become your problem.
The DC Council will likely soon vote on B26-0058, The Recycling Refund and Litter Reduction Amendment Act of 2025. If enacted, this bottle bill will have deep and enduring negative implications for beverage manufacturers, distributors, retailers, and consumers.
The bill’s current version defines “distributor” broadly, to include businesses that sell beverages to retailers in the District, including manufacturers selling directly to retailers, and grocery stores that produce store brands. Covered distributors would be required to register with the District, join a beverage container stewardship organization and be subject to costs and liabilities regardless of where their facilities are located.
Those costs could be substantial, reaching well into six figures annually for some distributors. And that is on top of the expense of new infrastructure, new reporting requirements, deposit accounting, container handling and other operational and compliance changes.
An independent cost analysis estimates the program would require approximately $58 million in startup investment and $38 million in annual operating expenses, with industry expected to shoulder much of the burden. These are substantial costs for a market of just 61 square miles that is dependent upon interstate beverage distribution more than any of the 10 states that currently have a container deposit program. The financial exposure for distributors alone should command the industry’s attention.
The burdens would extend directly into grocery stores. Under the proposal, most supermarkets and other retailers with more than 2,000 square feet would be required to accept used beverage containers for redemption. That means dedicating valuable retail space, equipment and staff time to collecting and storing dirty bottles and cans, introducing new sanitation, pest-control and operational concerns into businesses that sell food. Smaller retailers, restaurants and bars would be exempt from serving as redemption locations, but would still face the financial and logistical effects of the program.
The proposal also creates powerful incentives for redemption fraud. The District would require a 10-cent deposit while nearby states, such as Maryland and Virginia, have no comparable requirement, inviting bad actors to illegally redeem out of state containers in the District. Connecticut offers a cautionary example: after raising its deposit to 10-cents in 2024, the state has confronted cross-border redemption fraud, reported millions in losses to beverage distributors, and enacted tougher enforcement measures. By contrast, the District’s proposal, lacking comparable safeguards, forces distributors – including those located outside D.C. – to serve as its dedicated “Bottle Police”. Intentional underenforcement, fraud and funding shortfalls threatens the entire redemption program, leaving distributors inside and outside of the District to absorb the financial consequences.
As president of the District of Columbia Association of Beverage Alcohol Wholesalers, I have profound concerns about the DC Bottle Bill’s implications for our member distributors. Our members are part of a small community of wholesalers that still remain in DC, and who are required by law to warehouse and operate in the District itself. For distributors operating outside the District, the implications are similarly dire.
The DC Bottle Bill would force new compliance obligations and incur steep costs onto complex regional supply chains. Companies serving DC retailers would need to account for covered containers, comply with labeling and registration requirements, invest in infrastructure, and participate in the new untested stewardship system no matter where their warehouses or production facilities are located. On top of this, distributors will have the impossible task of “protecting” DC’s borders from the substantial influx of beverages that enter DC outside of the program’s reach. This includes DC’s high volume direct-to-consumer shipping market and purchases made outside of the District.
Distributors across the Mid-Atlantic and beyond need to understand what is being proposed in Washington DC, and what it could mean for their businesses. Companies serving the District should examine their potential financial, operational, and liability exposure, engage with their industry associations and make sure their concerns are part of the legislative debate.
And distributors elsewhere should pay close attention to the precedent being considered.
The District of Columbia may be a small market geographically, but the implications of this legislation extend far beyond its borders.
The industry’s stake in this debate is much bigger than DC.
Risa Hirao is President and General Counsel of the District of Columbia Association of Beverage Alcohol Wholesalers.