The Circular Action Alliance (CAA), which is the first Producer Responsibility Organization or PRO in California, held a EPR stakeholder webinar this week. Below is a recap of the California portion of the updates and you can view the presentation slides HERE (enter passcode: CAAUpdate3! to access the presentation).

As a reminder, CAA also hosts regular Producer Working Group Meetings for the implementation of SB 54, which the CRA team attends and provides recaps for our members (these meetings are not recorded). The next CAA Producer Working Group will be held Tuesday, February 20 at 12 pm ET/10 am MT/9 am PT. Register HERE. Participation is open to all producers, trade associations representing producers and legal counsel to producers.

For questions specific to CAA/the PRO, please reply to this email or send to cra@calretailers.com and we can share with CAA or you can reach out directly to info@circularaction.org.

CAA Stakeholder Webinar Recap

CAA will provide comments on CalRecycle’s draft regulatory rules during formal rulemaking process this year (which has not yet begun). CAA has also been appointed as a non-voting member of the SB 54 Advisory Board, which will hold its first meeting on Friday, Feb. 2 (CRA's President and CEO Rachel Michelin also serves on this Board).

Some of CAA’s SB 54 implementation plans are included in their PRO application, which can be viewed HERE. The application is also available on Cal Recycle’s website.

Q&A pertaining to CA:

Will the PRO have one final CMC list for all EPR states? CAA: There is no CMC list consistency across each EPR state. Goal if CAA is to harmonize the list by mapping CA’s list, which is the largest, against other states. There will be as much alignment as possible, but it will not be perfect. Stay tuned for updates on this.

Producer administrative questions for PRO. CAA: CAA has suggested something similar to CO for implementation in CA with regards to producer registration, which is a simplified process requiring only contact info by July 1, 2024 despite there not being a registration deadline specified in the regs in CA. Goal is to get as many producer registrations as possible to minimize free riders in the program and get a more accurate calculation and data set for administering the program. CAA is working on a Producer-PRO agreement as well.

Where can we find the EPR statue for each state? CAA: we link to each state’s statute on our website. https://circularactionalliance.org/

PRO’s role with states that have pending legislation related to EPR? CAA: we are implementing enacted EPR laws so while we keep tabs and track on legislation, we are not formally engaging in formal legislative processes or lobbying for specific definitions or determinations or providing updates on legislative state of play. Please work with your state’s trade associations and other advocacy groups on those specific needs. 

Question on LCAs: Life Cycle Analysis. Is Oregon the only state that incorporates LCAs in their state legislation? CAA: yes, they are the only state that formally requires LCAs, but other states may consider LCAs through eco-modulation approaches.