CRA Members:

The CRA team submitted comments yesterday on the second revision of draft SB 54 regulations to the Department of Resources Recycling and Recovery (CalRecycle) ahead of their public comment period deadline. READ CRA'S LETTER HERE. Our team also signed on to a large business coalition letter lead by the California Chamber of Commerce, which was also submitted yesterday. Read Cal Chamber's coalition letter HERE.

Thank you to our members for providing valuable feedback during this public comment period. Input from our industry leaders is crucial as the California Retailers Association has strategically positioned ourselves to have a unique opportunity to help shape the future of this state's historic packaging extended producer responsibility program.

As a reminder, CRA's President and CEO Rachel Michelin was appointed to the SB 54 Advisory Board providing a voice for the retail industry during the SB 54 rulemaking process. As such, we are looking to our members and their subject matter experts in taking advantage of every opportunity to weigh in on the regulations including the numerous Advisory Board meetings that have been held by CalRecycle to date.

The comments submitted today are in response to a 15-day comment period (extended three times), which followed an initial 61-day public comment period covering March 8 - May 8, 2024. These comment periods have resulted in two draft versions of SB 54 regulations. A final Statement of Reasons is expected next from CalRecycle, which has a statutory deadline to finalize regulations by January 1, 2025. View the SB 54 regulations ruklemaking and implementation timeline HERE.

For reference, CalRecycle's Notice of Extension of 15-Day Public Comment Period (Notice), the revised regulation text and rulemaking webpage are available below.

• Read the Notice HERE.
• Access the Rulemaking Webpage HERE.
• Download the Regulatory Text HERE.

SB 54 Draft PEIR - FEEDBACK NEEDED BY DEC. 19

On the deadline for the second round of public comments on draft SB 54 regulations, CalRecycle released a Draft Program Environmental Impact Report (PEIR). The public review and comment period for the Draft PEIR is from Nov. 4, 2024, through Dec. 19, 2024. Please send feedback on the SB 54 Draft PEIR to sarah@calretailers.com or by replying all to this email by Monday, December 16 as our team plans to comment on this piece of the regulations as well.