On November 4, RCRC submitted formal comments and suggested modifications to CalRecycle’s updated draft single use packaging regulations.
SB 54 (Allen) of 2022 requires manufacturers of single use packaging and food service ware to take responsibility for the management and recycling of the products they introduce into the stream of commerce. CalRecycle was required to determine which categories of covered materials are recyclable and compostable and SB 54 requires all local jurisdictions to include those materials identified by CalRecycle in their collection and recycling/composting programs (unless they receive an exemption or extension from CalRecycle). Those 19 counties with fewer than 70,000 residents (and cities within those counties) may exempt themselves from this requirement.
RCRC’s comments on the updated draft regulations acknowledge several significant improvements based upon suggestions made by RCRC and other stakeholders, but also raise concerns about other aspects of the proposal. RCRC outlined issues with the scope of expenditures eligible for reimbursement, the expensive dispute resolution process outlined to resolve differences between local governments and the producer responsibility organization, and the enforcement process.
RCRC anticipates that CalRecycle will have to make several additional changes and release a third draft that should be subject to another brief 15-day public comment period.
For more information, contact RCRC Senior Policy Advocate, John Kennedy.