Obligations of Large-Scale Brewers and Beer Distributors Regarding the Identification of Beer Containers
Beer containers sold or delivered by large-scale brewers and beer distributors to establishments authorized to sell alcoholic beverages for consumption on the premises must generally be identified.
This also applies to containers of beer that is:
- produced by a microbrewer that is associated with (for example, controlled by) a large-scale brewer
- produced by a microbrewer on request under an agreement with a large-scale brewer
- marketed by a beer distributor for which a large-scale brewer is acting as an agent and delivers all or part of the beer in question
Beginning on September 1, 2025, containers of beer produced by a microbrewer on request under an agreement with a large-scale brewer no longer have to be identified if the microbrewer is not associated with the large-scale brewer.
Large-scale brewers and beer distributors will have the following obligations:
- by august 1, 2025: file an information return listing the brands of beer they sell or deliver in Québec whose containers are identified, and keep the list up to date
- beginning September 1, 2025: on invoices, add “CSP” (consumption on the premises) next to each beer sold or delivered in an identified container or a note that all the beers on the invoice must be in identified containers
For more information, see the current version of interpretation bulletin TVQ. 677-1, Identification of Beer Containers, on the Publications du Québec website.
Effective September 1, 2025, beer containers sold or delivered by microbrewers no longer have to be identified, except in the above-mentioned cases. As a result, these containers will no longer have to be marked "CSP" or have the stamp approved by Revenu Québec if they contain beer that is intended for consumption in an establishment authorized to sell alcoholic beverages for consumption on the premises (for example, a restaurant or bar) or sold with prepared food for take out or delivery.
The exemption also applies to containers of beer marketed by distributors that have sold 15 million litres of beer or less in Québec annually over the last three calendar years.
Beer brands marketed by the Société des alcools du Québec (SAQ) or imported privately through the SAQ will not be listed in the public registry of beer brands whose containers must be identified. However, their containers must still be identified if they contain beer intended for consumption in an establishment authorized to sell alcoholic beverages for consumption on the premises. That said, the SAQ is not required to put “CSP” (consumption on the premises) on its invoices.
Filing the information return
Large-scale brewers and beer distributors must include a beer brand in their information return in the following cases:
- The beer is produced and sold by a large-scale brewer or sold by a large-scale distributor.
- The beer is delivered by a large-scale brewer or distributor, who is acting as an agent for an associated microbrewer or a beer distributor.
- It is produced for the brewer by another brewer (large-scale or micro) under an agreement.
Large-scale brewers and beer distributors must file the information return using the service for sending documents in My Account for businesses and update it any time a brand must be added or removed.
A register with this information will be available on our website by September 1, 2025.
Large-scale brewer status
To determine whether a person is a large-scale brewer, special rules apply in certain cases.
Person associated with a large-scale brewer
This means a person associated with another person (that is or becomes a large-scale brewer) within the meaning of the Act respecting the Québec sales tax. Generally, a person is associated with another person when one controls the other.
The number of litres of beer sold in a calendar year by such a person is the total number of litres of beer sold in the year by the person and the person they are associated with.
Corporation resulting from an amalgamation
This means a corporation resulting from a corporate amalgamation that sold an average of more than 15 million litres of beer annually over the last three calendar years.
The number of litres of beer sold by such a corporation is calculated as follows:
- for a calendar year before the amalgamation: add the number of litres of beer sold during the year by each amalgamated corporation
- for the calendar year of the amalgamation: add the number of litres of beer sold during the year by each amalgamated corporation and by the corporation resulting from the amalgamation
Person continuing a business
A person is considered to carry on another person's business if:
- The person acquired all or nearly all the business's assets
- It is reasonable to assume that because of the acquisition, the person will continue to carry on the business
To determine the number of litres of beer sold during the calendar in which the person continues to carry on the business or in a year preceding that calendar year, add the total number of litres of beer sold during the year by the person and by the other person's business.
Person that begins to carry on a business
This means a person, other than a corporation resulting from an amalgamation or a person continuing a business, that began to carry on a business in the three previous calendar years.
To determine the average number of litres of beer sold annually by such a person, take into account only the full calendar years in which the business was carried on.
Deadline
Any person that becomes a large-scale brewer on or after September 1, 2025, will have one year to comply with the obligation to identify beer containers. This will allow them to unload their unidentified containers sold or delivered to establishments authorized to sell alcoholic beverages for consumption on the premises.