FPA Signs Coalition Letter to CalRecycle on the Proposed Revisions to California's Senate Bill 54 Permanent Regulations

The undersigned entities (the “Coalition”) are appreciative of the opportunity to submit comments regarding California’s Department of Resources Recycling and Recovery’s (“CalRecycle”) proposed revisions to the Senate Bill 54 (“SB 54”) permanent regulations. Together, the Coalition represents virtually all aspects of the packaging value chain and some of the most integral stakeholders in the work that CalRecycle is undertaking to increase recycling in California. The permanent regulations will play a crucial role in enabling California’s extended producer responsibility program to meet the circularity targets established within the SB 54 statute, as well as in the ability of the regulated community to achieve their own, concurrent sustainability goals. SB 54 establishes ambitious circularity goals for producers; yet the proposed revisions to the permanent regulations contain a substantial oversight in their methodology for achieving these targets.