Producer Working Group Meeting #2

The Producer Working Group (PWG) is a monthly opportunity for producers, their legal representatives, and trade associations to learn about and discuss priority producer issues. Please do not share this content beyond the group.


December 5, 2023

Presentation

Key Takeaways

  1. Registration Timelines
    Colorado has included a July 1, 2024, registration deadline for producers in their draft rules. We expect other states to clarify registration deadlines and are preparing to register producers in multiple states in 2024 to ensure adequate time to prepare for data collection, reporting, and other requirements (e.g. preparation of plastic source reduction plans in California) 

    CAA will provide clarity about what registration entails for producers at a future Producer Working Group meeting. 

  2. Primary Producer Obligations
    CAA has identified six areas of producer responsibility to guide early producer planning:    

    1. Join the approved Producer Responsibility Organization (PRO)  

    2. Collect and report data to a PRO 

    3. Pay fees/dues based on reported data 

    4. Potential redesign of materials/delivery models (based on incentives) 

    5. Development of Plastic Source Reduction Plan** 

    6. Ensure materials are recyclable or compostable** 

    **California only. 

    Note: The first two items were covered in more detail during this PWG. The other obligations will be covered in future meetings.

  3. Obligation #2 - Data Collection & Reporting
    Finalized data reporting requirements are still months away, but companies need to start planning. Key factors to consider include:

    1. Which materials used by your company are in-scope in each EPR state? 

    2. Is your company likely to be considered the producer for these materials? Which ones? 

    3. How is each state categorizing material, as outlined through Covered Material Categories (CMC) lists? (i.e., California’s CMC List

    4. What eco-design considerations should producers account for? Some eco-design factors are outlined in statute, and CAA will continue to clarify requirements and incentives for producers. 

    Many of these factors are still in development through rulemaking processes. CAA will continue to provide guidance to producers through 2024. By joining CAA’s producer working group meetings, producers can ensure they are up to date on critical deadlines and reporting considerations.

Top Producer Questions

Next Meeting

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