What are the US beverage container deposit compliance requirements for UK-produced cans, and can the marking be printed on labels instead of etched?
For US exports, beverage container deposit compliance markings can be printed on the can label rather than requiring etching on the aluminium. This requirement became enforceable at state level from May 2024, with distributors able to refuse product or issue fines for non-compliance.
Key points members shared:
- **Label printing is acceptable** — the deposit compliance wording does not need to be etched into the can itself; printing on the label meets the requirement. - **State-specific deposit amounts** — Connecticut (CT) raised its deposit to 10 cents as of January, so labels must reflect the correct deposit value for each state where product is sold. Outdated labelling showing older deposit amounts creates immediate non-compliance issues. - **PFAS compliance is equally critical** — members emphasised that checking PFAS (per- and polyfluoroalkyl substances) compliance for US distribution is just as important as deposit marking. European suppliers only achieved PFAS-compliant availability at the end of 2023, so verify your canner's compliance status before exporting.
Cautions: US bottle bill requirements are state-specific and subject to change (as the CT example shows). Ensure labels are updated whenever deposit amounts change in your target states, and confirm your UK canner understands and supports these compliance requirements.
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