Ontario’s beverage alcohol wholesale system changed significantly in 2026 with the introduction of the LCBO’s more open wholesale listings process.

The changes create a new route for eligible alcohol products to reach Ontario grocery stores, convenience stores, hospitality licensees, LCBO Convenience Outlets (LCOs) and duty-free stores without necessarily first obtaining a traditional LCBO retail listing.

For domestic manufacturers, out-of-province producers, import suppliers and Ontario liquor agents, the Open Listings framework creates potentially significant new opportunities. It also introduces new requirements relating to product calls, LCBO registration, warehousing, supplying-source status, pricing, product eligibility, quality assurance and fulfillment.

This guide explains how the LCBO Open Listings process works, who can participate, and what businesses should consider before submitting an alcohol product for an Ontario wholesale listing.

The LCBO describes the initiative as a more open listings process intended to expand opportunities for suppliers to respond to product calls for its wholesale catalogues.

The objective is to allow suppliers to bring new products into the Ontario market more quickly, increase competition and provide greater product choice to Ontario consumers.

This is fundamentally a wholesale initiative.

The LCBO remains Ontario's exclusive wholesaler of beverage alcohol to wholesale customers. As of April 1, 2026, those customers include thousands of points of sale across grocery, convenience, hospitality, LCO and duty-free channels.

However, the LCBO no longer necessarily needs to physically warehouse and deliver every product sold through that wholesale system.

That distinction is central to understanding Open Listings.

Why Are Open Listings Important?

Historically, obtaining broad access to Ontario's alcohol market was closely connected to the LCBO's own purchasing, listing and distribution systems.

The new framework separates some of these functions.

An eligible product can be registered with the LCBO and placed in one or more wholesale catalogues while fulfillment and delivery may, depending on the product and supplier, occur through an approved Supplying Source rather than the LCBO's own distribution network.

The LCBO's online system still sits at the centre of the transaction: wholesale customers order through the LCBO, and the LCBO remains responsible for receiving payment from wholesale customers and providing payment to supplying sources for products purchased.

This potentially gives producers and agents access to wholesale customers without requiring the LCBO to make the same retail merchandising decision that would ordinarily be associated with obtaining shelf space in LCBO stores.

Open Listings Are Not the Same as an LCBO Retail Listing

This is one of the most important distinctions.

A product appearing in an LCBO wholesale catalogue does not necessarily mean that it will be carried in LCBO retail stores.

The wholesale catalogue is designed for licensed wholesale customers.

Suppliers can opt products into one or more applicable customer-group catalogues, including:

grocery stores;
convenience stores;
hospitality licensees;
LCBO Convenience Outlets; and
duty-free stores.

The LCBO's eligible product catalogue displays product information, operational attributes such as the supplying source, and wholesale pricing. It is updated daily.

Accordingly, a producer may be able to pursue sales directly with Ontario retailers or hospitality businesses even though the product is not sitting on the shelf of an ordinary LCBO retail store.

Domestic and Imported Products Have Different Open Listing Pathways

The Open Listings system distinguishes between domestic products and imported products.

That distinction has important consequences for who may act as the supplying source, how products are warehoused and how applications are made.

Domestic Alcohol Products

On June 1, 2026, the LCBO opened its expanded product calls for domestic products.

The change expanded the previous Ontario supplier call to include suppliers elsewhere in Canada. Suppliers can opt eligible products into one or more wholesale catalogues.

The 2026/27 domestic needs grid includes calls covering domestic wine as well as beer and cider, with additional product categories addressed in the grid. For grocery and convenience channels, products must satisfy the applicable eligibility requirements under Ontario Regulation 746/21 under the Liquor Licence and Control Act, 2019.

Imported Alcohol Products

The LCBO launched its import wholesale product calls on June 29, 2026.

The imported wine call, for example, covers non-LCBO-listed and eligible LCBO-listed imported wines for grocery, convenience, hospitality/licensees, LCO and duty-free channels.

Imported products have an additional structural requirement: an Ontario agent representing the products must first satisfy the requirements of the LCBO's Warehousing for Open Listings Program before submitting qualifying products through the import wholesale product call.

What Types of Alcohol Can Be Open Listed?

The LCBO's wholesale product-registration system operates through product calls organized by product category.

Those categories include:

beer;
cider;
wine;
spirits; and
ready-to-drink beverages (RTDs).

The LCBO Wholesale Supply and Delivery Procedures Manual states that product registration begins by submitting eligible products to an applicable product call in the New Item Submission System (NISS). Product calls are organized by both category and channel.

Being within one of these categories does not automatically make a product eligible for every retail channel.

Grocery and Convenience Store Eligibility Still Matters

Open Listings do not override Ontario's rules governing which alcohol products grocery and convenience stores are permitted to sell.

Products intended for those catalogues must meet applicable regulatory eligibility criteria.

Those requirements can involve matters such as:

product category;
alcohol by volume;
package size;
producer characteristics; and
applicable pricing treatment.

The LCBO specifically states that products must meet category definitions and regulatory eligibility requirements before they can be accepted through NISS.

A product might therefore qualify for one wholesale customer group while not qualifying for another.

How Do You Apply for an LCBO Open Listing?

The principal product submission system is the New Item Submission System, commonly called NISS.

At a high level, the process involves:

obtaining the necessary supplier, agent and/or supplying-source approvals;
identifying the appropriate wholesale product call;
submitting complete product information through NISS;
selecting the applicable wholesale customer catalogue or catalogues;
undergoing LCBO submission and eligibility review;
completing product setup;
satisfying compliance, labelling and laboratory requirements;
completing wholesale pricing; and
having the product activated in the applicable wholesale catalogue.

The LCBO's own process chart describes five broad stages: Product Submission, Submission Review, Product Set-Up, Compliance Review, and Wholesale Pricing and Activation.

Are the Open Product Calls Competitive Tenders?

The concept of an “open call” is important.

According to the LCBO's Open Listings FAQ, the calls remain open for a year and are renewed, with submissions reviewed on a rolling basis. Once the necessary warehousing and supplying-source approvals have been obtained, an eligible applicant can respond through NISS. The FAQ expressly states that applicants may apply at any time and that there is no deadline within that open-call structure.

The applicable needs grid should nevertheless always be checked because individual calls identify their operative opening and closing dates.

For example, the 2026/27 imported wine call opened June 29, 2026 and shows a March 31, 2027 closing date.

What Is the Supplying Source Program?

The Supplying Source Program is another key part of the new system.

An approved supplying source can fulfill and deliver products ordered by wholesale customers through the LCBO's ordering platform.

Supplying sources can include:

domestic manufacturers;
authorized agents; and
other entities authorized by the LCBO, such as The Beer Store.

Wholesale customers still place their orders with the LCBO. The supplying source then fulfills and delivers the applicable order itself or through a third-party logistics provider.

This is sometimes described as dropshipping.

The LCBO defines dropshipping as a model where the product moves directly from the supplying source to the customer rather than being physically stocked and shipped by the central online seller.

Can an Ontario Manufacturer Be Its Own Supplying Source?

Yes, subject to the applicable LCBO requirements.

Ontario suppliers can register directly to participate in the Supplying Source Program and may warehouse their products in accordance with the terms of their AGCO licence.

The LCBO framework also provides Ontario manufacturers with flexibility in choosing fulfillment arrangements. Depending on the product and customer group, fulfillment can potentially involve the LCBO, the manufacturer or The Beer Store.

What About Canadian Manufacturers Outside Ontario?

Out-of-province Canadian manufacturers have a different position.

They do not need authorization under the Warehousing for Open Listings Program simply to become a supplying source.

Instead, they may register directly for the Supplying Source Program if they can meet the applicable fulfillment requirements. The LCBO FAQ states that a domestic manufacturer must be capable of fulfilling and delivering products to wholesale customers within 14 days under the Service Level Agreement.

If an out-of-province manufacturer needs inventory stored in Ontario to meet that obligation, it may use a 3PL authorized under the Warehousing for Open Listings Program.

Imported Products Require an Authorized Ontario Agent

The import pathway is more involved.

An import supplier must first appoint an Ontario agent. That agent must hold an AGCO Licence to Represent a Manufacturer.

The agent then needs authorization under the LCBO's Warehousing for Open Listings Program. Once authorized, the agent can participate in the Supplying Source Program and submit approved products to the applicable Import Wholesale Product Call.

The agent must also have an agreement with an authorized 3PL unless it has its own qualifying warehouse that separately receives a Warehousing Authorization.

The Warehousing for Open Listings Program

The Warehousing for Open Listings Program was created to support the new distribution model.

It authorizes qualifying 3PL businesses to warehouse and distribute eligible imported and out-of-province domestic products. It also provides the authorization structure through which agents can work with the LCBO to import and warehouse products in Ontario.

For imported products, the structure generally looks like:

Foreign Manufacturer → Licensed Ontario Agent → LCBO Import Process → Authorized Ontario Warehouse/3PL → LCBO Wholesale Order → Wholesale Customer

Importantly, the LCBO remains the importer of record for products entering Ontario through this framework. Authorized agents work with the LCBO to coordinate importation and shipment.

What Does a Warehouse Need to Qualify?

The LCBO has imposed substantial eligibility requirements on 3PLs seeking a Warehousing Authorization.

Among other requirements, a qualifying 3PL must:

operate an Ontario warehouse;
hold a CRA Excise Warehouse Licence or, for import beer, an applicable CBSA Customs Bonded Warehouse Licence;
have at least 100,000 square feet or equivalent secure, temperature-controlled storage capacity;
have delivery capability;
maintain systems capable of accurately tracking inbound and outbound inventory; and
generally have at least five years of logistics experience supported by an experienced operational team.

The LCBO currently publishes authorized 3PLs participating in the program.

When Can Imported Inventory Be Brought Into Ontario?

An agent cannot simply warehouse imported alcohol and then decide later to seek an Open Listing.

The authorization structure comes first.

The LCBO's FAQ states that an agent must be authorized before participating in the wholesale open call. The applicant submits a product list and warehousing plan as part of the authorization process. Products from that approved list can then be submitted after authorization and supplying-source registration.

This is intended to ensure that an appropriate warehousing plan exists before imported inventory enters the program.

Can Products Be Stored Anywhere?

No.

Under the import Open Listings framework, products may only be stored at the warehouse identified in the authorization.

The LCBO also states that product generally may only be removed from the warehouse after it has been sold to a wholesale customer, unless the LCBO expressly permits otherwise. Inventory-movement records must be maintained and produced to the LCBO on request.

What Information Is Required in an Open Listing Submission?

Requirements vary by product call, but suppliers should expect to provide substantial product and commercial information.

For example, the 2026/27 domestic wine call requires complete product information and identifies requirements relating to:

supplier/vendor information;
UPC and SCC information;
product catalogue selection;
estimated wholesale price;
fulfillment preference;
label review;
final laboratory samples where applicable; and
forecasts for LCBO-supplied products.

The needs grid emphasizes that incomplete submissions will not be accepted.

Imported calls similarly require complete product information, catalogue selection, estimated wholesale pricing and a six-month wholesale sales forecast.

Product Labels and Quality Assurance Still Apply

Open Listing does not mean reduced product compliance.

Products listed for wholesale must comply with LCBO Product Packaging Standards and Chemical Guidelines, which incorporate federal and provincial compositional and labelling requirements.

Labels must also comply with applicable federal requirements and the AGCO's standards relating to matters such as brand, imagery, text and format. Failure to comply can result in removal from the wholesale catalogue.

Accordingly, suppliers should conduct their regulatory and label review before committing significant quantities of packaging or importing inventory.

How Does Wholesale Pricing Work?

The supplier does not simply choose the final amount charged to an Ontario wholesale customer.

According to the LCBO manual, wholesale pricing is calculated through a cost-plus formula incorporating applicable taxes, markups and fees into the supplier quote.

Wholesale markups apply across the relevant wholesale customer groups, including grocery, convenience, hospitality licensees, LCOs and duty-free.

Products must also comply with applicable statutory and regulatory minimum-pricing requirements.

This means suppliers should model their economics before applying. A product that appears commercially attractive based on its manufacturer's selling price may look very different after freight, warehousing, applicable taxes, LCBO pricing treatment and fulfillment costs are taken into account.

Who Actually Sells the Product to the Retailer?

Even where an agent or manufacturer performs fulfillment, the wholesale transaction continues through the LCBO system.

Wholesale customers are required to place beverage alcohol orders through the LCBO's online order-management system or another entity authorized by the LCBO, and they pay the LCBO for the products ordered.

This is an important distinction between selling and fulfilling.

An Ontario agent may solicit orders and maintain commercial relationships with retailers, but an agent does not simply independently sell the alcohol to the wholesale customer. The LCBO manual expressly distinguishes an agent's solicitation and marketing role from the wholesale sale itself.

Can Suppliers Market Directly to Grocery and Convenience Stores?

Yes, within the applicable legal and LCBO framework.

In fact, the LCBO places responsibility on suppliers and agents for pursuing sales, marketing relationships and commercial opportunities directly with wholesale customers.

That makes Open Listings commercially different from merely waiting for LCBO retail merchandising decisions.

A supplier can potentially approach eligible retailers, develop demand for its product and encourage those retailers to order it through the LCBO wholesale system.

The retailer, however, remains responsible for its own assortment and purchasing decisions.

How Quickly Must Supplying Sources Deliver?

The LCBO's general lead time for a supplying source other than The Beer Store is up to 14 days from placement to receipt of an order.

The Beer Store's lead time is up to seven days.

Supplying sources can use third-party logistics providers to make deliveries, and permitted delivery-related service fees may apply.

Reasonable minimum order quantities may also be established and communicated to wholesale customers through the LCBO ordering system.

Does the LCBO Issue a Purchase Order?

Yes.

For supplying-source transactions, the LCBO issues a purchase order to the applicable supplying source identifying the wholesale customer ship-to locations.

Those purchase orders are subject to the LCBO's standard Purchase Order Terms and Conditions for alcohol products.

Suppliers therefore need to understand that becoming a supplying source involves more than simply obtaining a listing. It creates ongoing contractual and operational obligations to the LCBO.

The Service Level Agreement Is Important

Participation in the Supplying Source Program requires onboarding and an agreement with the LCBO.

The LCBO's Service Level Agreement addresses matters including:

compliance with the Wholesale Supply and Delivery Procedures Manual;
listing and delisting;
order management;
shipping and delivery;
insurance;
quality complaints;
recalls;
traceability;
permitted delivery-related service fees; and
non-compliance penalties.

Businesses should therefore treat supplying-source onboarding as a substantive compliance and contracting exercise rather than a simple administrative registration.

What Happens With Existing LCBO Products?

Open Listings are not limited exclusively to completely new brands.

Existing eligible products can also be made available to wholesale customer groups through the applicable processes.

However, there are important limitations.

If an import or out-of-province domestic product is already available through LCBO retail, the LCBO FAQ states that it must remain LCBO-supplied for purposes of servicing LCBO retail stores and any wholesale customer group into which the supplier opts the product.

The LCBO can also decline products that are identifiably the same as continuously available LCBO SKUs merely presented in another format or packaging configuration. Private-label products are not eligible under the FAQ.

What About Vintages Products?

There is also an important limitation involving Vintages releases.

Products with upcoming Vintages releases are not eligible for the Open Listing calls. A supplier can choose the Wholesale or Vintages Release program, but cannot have the same product in both simultaneously due to the limited-release nature of Vintages.

After Vintages inventory has fully sold through, the supplier can then proceed with a wholesale application.

How Long Does an Open Listing Take?

The LCBO's FAQ states that onboarding and product setup for new item submissions typically takes approximately 8–12 weeks, assuming timely and accurate information is provided.

That does not necessarily mean the product will physically be available within 8–12 weeks.

Once a purchase order is issued, actual inventory arrival depends on supplier readiness and shipping lead times. Products originating in countries with longer supply chains may take several additional months to arrive.

Businesses should therefore distinguish between:

listing approval → product activation → import/production → inventory availability → retailer delivery.

These are separate stages.

Why Open Listings Could Be Significant for Smaller Alcohol Brands

The commercial significance of the new framework may be substantial.

A small brewery, winery, cidery, RTD producer or international brand may no longer need to think about Ontario solely in terms of securing conventional LCBO retail shelf space.

Instead, a business may potentially develop an Ontario strategy focused on particular wholesale channels—for example:

independent grocery stores;
convenience chains;
restaurants and bars;
duty-free stores; or
particular geographic markets.

The ability to choose wholesale customer groups and, in some cases, fulfillment arrangements creates considerably more flexibility.

But it also shifts more commercial responsibility toward suppliers.

Being listed does not mean retailers will order the product.

Suppliers and agents still need to generate demand, develop wholesale relationships, manage inventory and meet the operational requirements associated with supplying those customers.

Open Listing Does Not Mean Open Distribution

The name can be misleading.

Ontario has not created an unrestricted private alcohol distribution market.

The LCBO remains the exclusive wholesaler, eligible products must be registered with the LCBO, customers order through the LCBO system, product and pricing requirements continue to apply, and suppliers participating in direct fulfillment must operate within the Supplying Source framework.

For imports, the controls are even more substantial because agent authorization, LCBO importation and approved warehousing arrangements must be established.

The better way to understand Open Listings is therefore as an expanded LCBO wholesale marketplace with decentralized fulfillment options, rather than deregulation of Ontario's liquor wholesale system.

Legal and Regulatory Considerations Before Applying

Alcohol businesses considering Open Listings should assess the entire structure before submitting a product.

Depending on the circumstances, this can include:

manufacturer licensing;
AGCO agent licensing;
appointment-of-agent agreements;
LCBO agent authorization;
Warehousing for Open Listings authorization;
supplying-source onboarding;
Service Level Agreements;
third-party logistics agreements;
excise licensing and duty;
product eligibility;
minimum pricing;
wholesale pricing;
federal and provincial labelling requirements;
packaging requirements;
advertising and promotion;
product recalls and traceability;
insurance;
retailer arrangements; and
import requirements.

For foreign manufacturers in particular, choosing the Ontario agent and warehousing structure can become an important part of the brand's overall Ontario market-entry strategy.

Frequently Asked Questions About LCBO Open Listings

What is an LCBO Open Listing?

An Open Listing is part of the LCBO's expanded wholesale listings framework that allows eligible products to be submitted through open wholesale product calls and, if approved, made available through applicable LCBO wholesale catalogues.

Does an Open Listing put my product in LCBO stores?

No. A wholesale Open Listing does not itself mean the product will be sold through ordinary LCBO retail stores. It makes the product available through selected wholesale customer catalogues.

Can a product be listed only for grocery stores?

Suppliers can select applicable wholesale customer groups during the listing process, subject to product eligibility and other regulatory requirements.

Can a product be sold to restaurants through an Open Listing?

Eligible products can be made available through the hospitality-licensee wholesale catalogue.

Can an out-of-province Canadian producer participate?

Yes. The expanded domestic calls include qualifying Canadian products from outside Ontario. Out-of-province manufacturers using the Open Listings process generally participate through the Supplying Source Program.

Can a foreign winery or brewery apply directly?

Imported products require an Ontario agent. The agent must hold the appropriate AGCO licence and obtain the necessary LCBO authorization before participating in the import wholesale product call.

Does an imported product need an Ontario warehouse?

The Open Listings import model requires an approved warehousing arrangement. The authorized agent generally works with an authorized Ontario 3PL, although an agent with its own qualifying facility can seek a Warehousing Authorization for that facility.

Who imports the alcohol?

Under the Warehousing for Open Listings framework, the LCBO remains importer of record for imported products entering Ontario.

Who delivers Open Listing products?

It depends on the product and fulfillment arrangement. An approved supplying source may fulfill and deliver itself or use a third-party logistics provider. Some eligible domestic products may instead be LCBO supplied.

How long does an LCBO Open Listing application take?

The LCBO states that onboarding and product setup for new submissions typically takes approximately 8–12 weeks, although inventory and shipping timelines can make actual market availability longer.

Does an Open Listing guarantee sales?

No. Registration makes the product available for eligible wholesale customers to order. Suppliers and agents remain responsible for developing sales and marketing opportunities, while wholesale customers decide what products and quantities to purchase.

How Substance Law Can Help With LCBO Open Listings

The Open Listings framework creates significant new opportunities for Canadian and international alcohol businesses seeking access to Ontario's expanded private retail and hospitality market.

It also sits at the intersection of LCBO policy, AGCO licensing, Ontario liquor law, federal excise requirements, importing, warehousing, distribution and commercial contracting.

Substance Law assists alcohol manufacturers, suppliers, importers, agents, distributors and other industry participants with matters including:

LCBO Open Listing strategy and applications;
NISS and wholesale product-call requirements;
AGCO manufacturer and agent licensing;
Warehousing for Open Listings requirements;
supplying-source arrangements;
manufacturer-agent agreements;
3PL and distribution arrangements;
alcohol product eligibility;
liquor labelling and packaging;
pricing and promotion requirements;
excise licensing;
importation issues; and
ongoing Ontario liquor regulatory compliance.

For businesses considering using the LCBO Open Listings process to introduce a new alcohol product into Ontario—or expand an existing product into grocery, convenience, hospitality or other wholesale channels—legal and regulatory planning should ideally begin before the product is submitted, inventory is manufactured or imported, and warehousing commitments are made.

What Are LCBO Open Listings?