Revised Plastic Container Rules Take Effect

Rigid Plastic Packaging Containers affecting direct sales, retail sales and remote sales through distributors and/or wholesalers' and through the internet.  

Revised regulations from the California Department of Resources Recycling and Recovery (CalRecycle) have gone into effect that are intended to decrease the use of new plastic and increase the use of recycled postconsumer plastic to manufacture rigid containers - potentially affecting a number of CAWA and AAIA  manufacturer and distributor members.

At issue are a wide variety of variety of rigid plastic packaging containers, or RPPCs, such as bottles, buckets and the clamshells often found enclosing or protecting many automotive products.  CalRecycle has notified a number of product manufacturers through a notice in the mail that informs the company they have been identified as a product manufacturer that sells or offers for sale products in California which are held within Rigid Plastic Packaging Containers - including direct sales, retail sales, and remote sales through distributors wholesalers' and the internet.  

CalRecylce is requiring companies to register within 90 days of receiving a notice through a web site that contains the RPPC container determination tools to determine whether registration requirements.
According to the CalRecycle web site www.calrecycle.ca.gov/plastics/rppc/#rppc a regulated RPPC sold in California must meet at least one of the following criteria:

• - It must be made from at least 25 percent postconsumer plastic;
• - The container weight must be reduced by at least 10 percent;
• - The RPPC must be 'reusable' and routinely reused at least 5 times; or
•     It must be recycled at a 45 percent recycling rate.

• Product manufacturers must register with CalRecycle.  To ensure compliance, visit CalRecycle's registration web page at www.calrecycle.ca.gov/plastics/RPPC/register.htm;
• Product manufacturers that sell products in RPPCs in California are responsible for using compliant RPPCs.  California sales include remote sales through distributors and/or wholesalers' and through the internet;
• The RPPC must be capable of at least one closure (including closure during the manufacturing process);
• The "reusable" term not excludes containers that store original products for sale; and
• Manufacturers cannot switch to using a different plastic resin in an RPPC to achieve a 10 percent weight reduction.