There are some situations where a contract bottler will typically be identified as a First Supplier.
Contract bottlers may be first suppliers if they are in operational control of beverages that they are bottling, for example if a supplier can order the bottled beverages directly from the contract bottler.
The contract bottler would not generally be considered a First Supplier in circumstances where they are providing bottling services for a third party, and they do not have the rights to sell the product to another entity or otherwise deal with the product.
Where a retailer engages a contract bottler to produce their private label beverages, the retailer themselves would likely be considered the first supplier.
Contract bottlers who supply their own beverages in their own containers would also be considered First Suppliers for those containers.
A contract bottler may also be considered as first supplier for a once-off product test run or promotional item that is produced, for example for a company that does not ordinarily supply beverages to market. The contract bottler and the company should document their agreed arrangement for being the First Supplier and clearly outline the expiration date for the arrangement.
If in doubt, contact Recycling Victoria for guidance via [email protected]