Rigid Plastic Packaging Container (RPPC) Violations and Penalties
CalRecycle is authorized to enforce the California Rigid Plastic Packaging Container law
- Violations of the RPPC law are a public offense and are punishable by a fine not to exceed $100,000 per calendar year.
- Container manufacturers that provide product manufacturers with false or misleading information can be found in violation of the RPPC law.
- The container manufacturer will be subject to the same penalties and fines imposed upon product manufacturers should CalRecycle determine that a container manufacturer provided false or misleading information.
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For product manufacturers submitting false or misleading compliance certifications, CalRecycle may:
- Issue fines and penalties
- Refer the violation to the Attorney General for prosecution for fraud
Types of Violations and Penalties
Late or Nonsubmittal
All three phases of the certification process are subject to penalties. If a product manufacturer fails to respond by the due date outlined in the certification cycle notice, the following penalties can be assessed.
| Days Late | Penalty Amount |
|---|---|
| 1–30 | $1,000 |
| 31–60 | $5,000 |
| More than 60 (Considered nonresponsive) | Up to $50,000 |
To avoid penalties, an extension of up to 30 days can be requested. The request for an extension must be received prior to the due date specified in the certification notice.
Incomplete/Inaccurate Certifications
Product manufacturers that submit an incomplete or inaccurate certification may be found non-compliant.
Examples of incompleteness or inaccuracy include, but are not limited to:
- Misreporting exemptions
- Failure to account for all products
- Failure to account for subsidiaries and divisions
- Lack of container manufacturer’s verification of weight of containers
- Missing container data
- Inconsistencies in information between product manufacturer and container manufacturer
- Lack of signatures
- Mathematical inaccuracies
This type of violation is subject to a penalty ranging between $1,000 and $50,000 in addition to civil penalties of up to $50,000 per violation. The penalty is determined by the degree and significance of incompleteness or inaccuracy. CalRecycle will calculate penalties using reported data and the formulas found in 14CCR section 17949 (g).
Container Compliance Option Violations
If a product’s RPPC does not comply with any container compliance options, the product manufacturer may be found non-compliant, subject to a penalty ranging between $5,000 and $50,000 in addition to civil penalties of up to $50,000 per violation. The penalty is determined by the degree of non-compliance.
CalRecycle will calculate penalties using reported data and the formulas found in 14CCR section 17949 (e).
Submittal of False or Misleading Information
Product manufacturers or container manufacturers who submit false or misleading information can be found in violation, subject to:
- A penalty of up to $100,000 and
- The referral of the case to the Attorney General for prosecution for fraud.
CalRecycle will calculate penalties using reported data and the formulas found in 14CCR section 17949 (e).
Public Notice of Violations (14CCR Section 17949 (c))
CalRecycle’s enforcement orders webpage provides links to RPPC enforcement orders and related actions taken since 2006 and fulfills the requirements of Government Code Section 6253.8.
The following are the historic RPPC enforcement orders and related actions taken prior to 2006:
2005 RPPC Certification Cycle Penalties
2005 RPPC Certification Cycle Penalties
| Company Name | Agreement Number | Type of Penalty | Amount of Penalty |
|---|---|---|---|
| PETCO Animal Supplies | No agreement executed. | Container Violation | $42,025.23 |
| Office Max | No agreement executed. | Container Violation | $34,350.61 |
| Sony Corporation | No agreement executed. | Container Violation | $50,000.00 |
| Total: $126,375.84 |
2002-2004: Compliance certifications not conducted.
2001 RPPC Certification Cycle Penalties
2001 RPPC Certification Cycle Penalties
| Company Name | Agreement Number | Type of Penalty | Amount of Penalty |
|---|---|---|---|
| Food for Less | IWMA 05-2005-07 RPPC | Late Certification | $1,000.00 |
| Golden Artist | IWMA 05-2005-08 RPPC | Container Violation | $5,000.00 |
| Henkel Corporation | IWMA 05-2005-10 RPPC | Container Violation Inaccurate Certification | $1,439.23 $5,000.00 |
| Office Max | IWMA 05-2005-15 RPPC | Container Violation | $40,259.16 |
| PETCO Animal Supplies | IWMA 05-2005-17 RPPC | Late Certification Container Violation | $5,000.00 $8,410.62 |
| Rite-Aid Corporation | IWMA 05-2005-18 RPPC | Late Certification | $1,000.00 |
| Sony Corporation | IWMA 05-2005-22 RPPC | Container Violation | $50,000.00 |
| Walgreen Company | IWMA 05-2005-27 RPPC | Late Certification | $4,000.00 |
| Total: $121,109.01 |
1997, 1998, 1999, 2000 RPPC Certification Cycle Penalties
1997, 1998, 1999, 2000 RPPC Certification Cycle Penalties
| Company Name | Agreement Number | Type of Penalty | Amount of Penalty |
|---|---|---|---|
| Beacon | IWMA 11-2000-01 RPPC | Inaccurate Certification Container Violation | $11,859.00 |
| Holmes Group | IWMA 11-2000-02 RPPC | Container Violation Inaccurate Certification | $15,000.00 $25,000.00 |
| ITW Dymon | IWMA 05-2005-30 RPPC | Container Violation Inaccurate Certification | $15,000.00 $1,000.00 |
| Total: $67,859.00 |
The information provided on this page is an overview of the Rigid Plastic Packaging Container (RPPC) law and regulations. It does not replace the requirements specified within them. Always refer to the full text of the regulations and statute, to ensure full compliance.
Phone: (916) 341-6717 | Email: RPPC@calrecycle.ca.gov | Fax: (916) 319-7337