Producer Working Group Meeting #6

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.

April 15, 2024

Presentation

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Key Takeaways

  1.  CAA Priority List of Comments on California’s Draft Rules. After reviewing the draft regulations, CAA prioritized five issues that represent either an operational or technical barrier to implementation of SB 54 and were the most salient with other stakeholders. CAA’s comments on these issue areas will be submitted to CalRecycle along with additional comments on other areas of the SB 54 rules. CAA’s priority list is: 

    1. Reporting and registration requirements for producers;
    2. A crystal-clear definition of obligated producer;

    3. Flexibility in producer reporting for the source reduction baseline calculation;

    4. Alignment of obligated packaging scope to PRO recycling infrastructure funding; and

    5. Clarity on the PRO’s cost coverage and funding mechanism for the recycling system.

     Detailed explanations of these priorities are outlined in the above presentation deck.

  2. Obligated Producers Must Register with CAA by July 1, 2024. Companies that expect to be considered producers under EPR laws for paper and packaging in California, Colorado, and/or Oregon should register with CAA by July 1, 2024. Starting in June, only registered producers may participate in CAA’s Producer Working Group, which meets monthly to review developments in the implementation process and steps producers need to take to comply with the laws. 

Top Producer Questions

For a more Frequently Asked Questions, please visit CAA’s FAQ page.

  • CAA’s deadline for producer registration is July 1, 2024. Early producer registration is critical to ensure CAA can begin to educate producers about data preparation and collect supply data to inform accurate fees rates for producers. To support the registration process, CAA will be closing the Producer Working Group to producers that are not registered. Trade associations, service providers and legal counsel may still participate in the Producer Working Group. You can learn more about producer registration and fill out the form on CAA’s Registration Page.

  • Producers will need to report and pay fees to CAA based on state-specific reporting requirements and fee schedules. However, if CAA is approved across EPR states, producers can provide state-specific data reporting and fee invoicing through a single reporting portal.

  • These materials are generally in scope in California and Oregon, unless a producer has received an exemption from the state regulator.

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