Audit, Compliance and Risk Blog

The California Department of Resources Recycling and Recovery (CalRecycle) has published a revised set of proposed regulations to implement 2022’s Senate Bill (SB) 54, the “Plastic Pollution Prevention and Packaging Producer Responsibility Act.” (I wrote about the legislation HERE). The Act phases in a ban on non-recyclable single-use plastics by 2032, and requires that threshold proportions of single-use items sold as “recyclable” will actually be recycled. Its implementation will make use of “extended producer responsibility” (EPR) mechanism similar to those used in California and elsewhere for other enhanced recycling programs (I’ve written about these before, most recently HERE). The remainder of this note discusses the proposed regulations and SB 54’s provisions. 

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California has just enacted the first statewide “extended producer responsibility” (EPR) law addressed to “apparel” and “textile articles” (“Responsible Textile Recovery Act of 2024” (SB 707, Newman). SB 707 will require manufacturers of targeted materials to ensure their recovery and recycling. California’s new program will be administered by the state Department of Resources Recycling and Recovery (CalRecycle), which oversees solid waste management (including recycling and other EPR programs) in the state.  The EPR approach to recycling – also called “product stewardship” –has been extending to new waste streams in recent years; the national advocacy group Product Stewardship Institute identifies 141 such programs spread among 33 US states (I provide an overview of these US state efforts HERE). The remainder of this note summarizes this new law. 

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