FPA Submits Comments for California’s SB 54 Plastic Pollution Prevention & Packaging Producer Responsibility Act Draft Regulations

The Flexible Packaging Association (FPA) is submitting these comments on CalRecycle’s Draft Proposed Regulation Text for Plastic Pollution Prevention and Packaging Producer Responsibility Act Regulations (hereinafter referred to as “Proposed Regulations”). FPA recognizes that these comments are in response to SB 54, but strongly encourages CalRecycle staff to take a holistic view of California’s recycling system and the modifications being made to it, particularly by SB 54 and SB 343. Because CalRecycle has not determined how it will implement SB 343, it is impossible to make fully informed comments on SB 343 and vice versa. Despite this fact, these two laws must be considered and implemented practically and cohesively to ensure the recycling system is appropriate for modern materials.