The Quebec government has announced that, effective September 1, 2025, the obligation to mark beer containers no longer applies to containers of beer sold or delivered by holders of a brewer's or beer distributor's permit issued under the Act respecting the Société des alcools du Québec who have sold 15 million litres or less of beer annually in Quebec over the last three calendar years. These containers will no longer have to be marked "CSP" (consumption on the premises) or have the stamp approved by Revenu Québec if they contain beer that is intended for consumption in an establishment that authorizes the sale of alcoholic beverages for consumption on the premises (for example, a restaurant or bar) or sold with prepared food for take out or delivery.

However, the marking obligation will be maintained for beer containers sold or delivered by holders of a brewer's or beer distributor's permit who have sold more than 15 million litres of beer annually in Quebec over the last three calendar years. Note that, when the Société des alcools du Québec sells beer to the holder of a bar, restaurant or accessory permit, it must continue to mark the containers with its stamp.

Brewers subject to the marking obligation must also:

• by August 1, 2025, provide Revenu Québec with a list of all the brands of beer they sell or deliver in Québec whose containers must be marked (including those they deliver as agents for a beer distributor);
• keep the list up to date;
• on all invoices, include "CSP" next to each beer sold or delivered that must be in a marked container or specify that all the beers sold or delivered must be in marked containers.

Special rules will apply to determine whether a person is a brewer subject to the marking obligation, particularly in the case of associated corporations, corporate mergers and the continued operation of another person's business by the brewer. Any person who becomes a brewer subject to this obligation will be given up to one year to comply with it so that they can sell their stocks of unmarked containers for delivery to establishments authorised to sell alcoholic beverages for consumption on the premises.

More details will be published on our website.