On January 8, CalRecycle announced that it approved Circular Action Alliance (CAA) to serve as the first producer responsibility organization (PRO) for the implementation of SB 54, the Plastic Pollution Prevention and Packaging Producer Responsibility Act. Enacted in 2022, SB 54 created an extended producer responsibility (EPR) program to manage packaging and single-use plastic foodware products in California. A PRO is responsible for managing program compliance.
SB 54 applies to “producers,” which is broadly defined to include manufacturers, that are the brand owners or licensees of the brand, of a product using “covered materials.” However, to ensure compliance, if there is no person in the state who meets that criteria, SB 54 will look downstream, potentially ensnaring the brand owner alone (e.g., private label retailers), distributors or retailers of products that use “covered materials”.
SB 54 initially set a January 1, 2024, deadline for producers of a covered material to join a PRO. Because CAA has only just been selected, there is currently no procedure for producers to join the PRO, but it is anticipated that one will be established soon. In the interim, CAA has created a working group allowing producers to participate in policy discussions that will inform the creation of the producer responsibility plan. Participation in the working group is an excellent way to keep abreast of the changes related to SB 54 as well as keep track of compliance obligations.
Producers are encouraged to join the working group as soon as possible, and ideally by Jan. 15 in time for the next meeting on Jan. 16.
To learn more about SB 54, the law’s requirements and the CAA working group, please read the full article on our website.
Please let us know if you are interested in participating in the working group through RJO. We would be happy to facilitate this and answer any questions you may have. You can contact the lead lawyer on your team or reach out to our Retail practice co-chairs, Alecia Cotton and Alexis Morris, or shareholder Jon-Erik Magnus.
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Budding food techie | NIFTEM-K
3wGreat initiative!! Conventional bottle and container caps contributes to 1/6 of the total plastic pollution. Lets see how it impacts the packaging industry.