Yesterday California’s Department of Resources Recycling and Recovery (CalRecycle) released guidance for source reduction reporting under SB 54, the Plastic Pollution Prevention and Packaging Producer Responsibility Act, also known as the Packaging EPR law. (Available here). The guidance provides producers with information regarding the Law’s plastic packaging reduction targets and how to track and report key data. The Circular Action (CAA) expects producers to submit their individual source reduction plans by August 3rd.
What Is the New Guidance?
The Source Reduction Reporting Guidance provides instructions and examples to estimate and reporting the weight and number of plastic packaging components covered by the law.
Why Does This Matter?
Under the law, producers must collectively reduce plastic packaging by:
- 10% by 2027
- 20% by 2030
- 25% by 2032
The law also provides five methods that producers can use to meet these reduction targets which are:
- Shifting to reusable or refillable options;
- Eliminating plastic packaging;
- Using more efficient plastic packaging;
- Replacing plastic with non-plastic materials; and
- Increasing the use of post-consumer recycled content.
Reduction targets are compared to the 2023 baseline data and the CAA is tasked with developing the plan and strategy to meet these targets. The targets do not apply specifically to each individual producer or equally across all packaging types.
This guidance is beneficial for covered producers with extensive product lines and/or complex packaging schemes. Implementing a strong data collection program with diligent efforts at packaging reduction now will help producers plan strategically, minimize risks, and potentially gain a competitive edge during the transition to more sustainable packaging.
If you have questions on legal and business strategies for compliance with the source reduction plan or the law in general, please contact Jake Bartlett or your Vorys attorney.