The California Retailers Association gave public comments today during CalRecycle's public workshops for the California Beverage Container Recycling and Litter Reduction Act (SB 1013) and the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54), which are now in the rulemaking process. Included with both of our comments was a request for CalRecycle to consider the impact these regulations will have on retailers, particularly with the associated costs in compliance. We urged CalRecycle to consider the impacts these regulations will have on business throughout the state if the Agency does not identify or allocate funding to offset growing program management and implementation costs.

Key points made during public comment:

SB 1013

• Inconsistent enforcement and local requirements will impact business operations.
• Varying degrees of enforcement and fines levied on business by local municipalities could result in additional costs for grocery stores.
• Clarity needed from CalRecycle on the compliance process and how to ensure that items are properly recycled while dealing with the inconsistencies in enforcement across the state.

SB 54

• Health hazards and increased costs associated with proposed regulations
• Labor compliance costs
• The potential to overwhelm retailers with separate programs for dozens of products
• Overly burdensome regulatory costs that will ultimately get passed down to consumers at a time of increased economic volatility.

The SB 1013 workshop included a timeline for the regulatory process, an overview of Dealer Cooperative concepts, Dealer registration information, Redemption Plan approval, amendments and updates and proposed Dealer Cooperative Reporting. For more information on today's SB 1013 workshop including the powerpoint presentation click here.

The SB 54 workshop included an overview of regulatory definitions and a review of covered materials and covered material exemptions. For more information on today's SB 54 regs workshop including the discussion document click here. The next SB 54 public workshop will be on May 31, 2023.