I object to and oppose this petition that would regulate a cost recovery method that has been ruled on, approved and implemented very recently, which would prohibit wholesalers from adopting pricing that enables them to recover the costs associated with fulfilling bottle business in Virginia.
A substantial cost for bottle versus cases processing include, but is not limited to -
Regulation 3 VAC5-30-90 allows for costs to be recovered and these are true ADDITIONAL costs incurred. The decision to impose a split case charge should remain an individual wholesaler’s business decision.
As part of a multi-state family owned company, I can add that in the twenty-two states that RNDC operates in, this is and has been in place for years and is an accepted cost recovery method. I can also add that the largest wine producing an consumption state in the US,California,also utilizes a bottle charge.
Thank you for your consideration.
Sincerely,
Gary Archuleta
Exectutive Vice President
Republic National Distributing Company of Virginia