California’s extended producer responsibility for packaging requirements under SB 54 are becoming a closer reality. One of the upcoming milestones will be a producer responsibility organization-wide target for reducing overall weight and number of plastic components by 10% come Jan. 1, 2027.
Producers’ individual source reduction plans based on 2023 data were due to producer responsibility organization Circular Action Alliance in early August, outlining a path forward via some combination of eliminating material, implementing reuse and refill, lightweighting, substituting materials or incorporating PCR.
California regulators won’t actually receive any of that individual producer source reduction information. Data that CalRecycle does see would be anonymized through what CAA reports in its program plan, Linnea Whitney Skierski, deputy director in the Office of Policy Development and Analysis at CalRecycle, during a panel at the SPC Advance conference in San Diego last week.
“Nobody is going to be held specifically accountable to meeting certain source reduction requirements. You're supposed to work together as a team to identify the best opportunities that would work for you,” she said.
Ultimately, there’s a PRO-wide 25% source reduction goal pegged to 2032, 10% of which must come from transitioning to reusable and refillable solutions. The PRO-wide approach recognizes that there’s more low-hanging fruit for some brands and product types than others.
Ellie Moss, executive director of nonprofit reuse firm Perpetual, delved into examples within food service. Moss noted “sheer terror” from many producers when it comes to implementing reuse, but noted that there are untapped changes that consumers won’t even see, such as in B2B transit packaging for back-of-house food delivery.
“You're getting buckets of pickles, you're getting big tubs of mayonnaise, you're getting these very large, often very heavy pieces of packaging that are then going straight to the dumpster, but could absolutely be refilled,” she said.
Stakeholders expect this will be increasingly relevant in other packaging EPR states, too, as there are source reduction targets in Minnesota, Washington and Maine, with potential for harmonization in future states.
CAA has been developing and tweaking a detailed incentive structure related to the source reduction goal. Dave Lefebvre, policy advisor with CAA, noted producers will be asked to submit individual source reduction plans each year if they have an update. “That task will allow us to dial in the right incentives to pursue the targets as quickly as possible, but as economically efficient as possible,” he said.
CAA’s revised program plan is due to CalRecycle next Tuesday and there will be an SB 54 advisory board meeting next Friday. “Our primary focus on ecomodulation is accelerating source reduction,” said CAA Chief of Staff Shane Buckingham in a Q&A on implementing California's packaging EPR program at SPC Advance.
