Understanding California's RPPC Law
California's Rigid Plastic Packaging Container (RPPC) Law is designed to reduce plastic packaging waste and increase recycling by requiring increased Producer Responsibility for Recycling of their products. The RPPC law achieves these objectives by requiring the producers of specified packaging sold in California meet minimum recycling criteria, including the utilization of not less than 25 percent recycled content. Minimum recycled content policies increase recycling by creating market demand for post-consumer plastic. The RPPC law was initially implemented in 1995 and is now administered by CalRecycle.
Update: CalRecycle recently adopted new regulations regarding the RPPC program, effective January 1, 2013. Visit the CalRecycle website.
What is Covered
The law defines a rigid plastic container as meeting the following requirements:
- It is made entirely of plastic except for lids, caps, or labels. (NOTE: the adopted revisions include other non-plastic incidental packaging components such as hinges)
- It has a capacity of at least 8 fluid ounces but no more than 5 gallons.
- It can maintain its shape while holding a product.
- It is capable of multiple reclosures and has an attached or unattached lid or cap. (NOTE: the adopted revisions include heat-sealed closures)
Containers designed specifically for shipping drugs, medical devices, cosmetics, food or infant formula are exempt from the law, as are containers designed to ship toxic or hazardous products, as defined by federal law.
What the Law Requires
The law defines the manufacturer of the container to be the company name that appears on the logo of the container. Manufacturers of RPPCs that are sold or offered for sale in California must meet one of the following requirements:
- The container is at least 10 percent source reduced, as defined.
- The container is comprised of at least 25 percent recycled content.
- The container is refillable or reusable at least five times, as defined.
- The container has a 45% recycling rate for either particular type or product specific containers.
Additionally, manufacturers may average one of the three requirements from #1-3, as defined. Producing a container that is recyclable does not fulfill these requirements. In 2004 the law was amended to repeal the requirement for CalRecycle to annually publish recycling rates for all RPPCs.
How the Law is Implemented
Manufacturers of RPPCs sold or offered for sale in California must sign a statement saying that they have met the requirements of the law. CalRecycle regularly reviews a select, random group of manufacturers to ensure they are meeting the RPPC requirements.