Container Determination Tools: Rigid Plastic Packaging Container (RPPC) Program

The following includes an overview of the RPPC law and regulations; it does not replace the requirements specified within them. Always refer to the full text of the statute and regulations, to ensure full compliance.

• Overview
• Self-Determination
• Examples of Regulated RPPCs
• RPPC Exemptions
• Determining a Container’s Volume or Equivalent Capacity

Overview

The following will help product manufacturers determine whether their product’s RPPC is subject to the laws.

A product manufacturer with several products will need to evaluate each product’s packaging independently.

Self-Determination

CalRecycle developed two self-determination tools for product manufacturers:

• Quick checklist ( PDF | Word) with three questions regarding a product’s packaging.
• Expanded Self-Determination Checklist (PDF | Word) to be used if additional review is necessary after using the quick checklist.

All product packaging container determinations are made on a case-by-case basis.

Examples of Products in RPPCs

RPPCs are used by a diverse community of product manufacturers. The products include, but are not limited to:

• Lubricants
• Sealants
• Automotive Products
• Electronics
• Office Supplies
• Toys

Examples of Regulated RPPCs

The RPPCs used by product manufacturers range in shape, color, size, and form. RPPCs can include, but are not limited to, the examples below (most photos include rulers to represent container height and width):

Jugs. The example jug is opaque and cylindrical with a built-in handle and funnel top, featuring a threaded cap.

Bottles (both wide mouth and narrow neck). The example is an opaque cylindrical RPPC bottle and lid.

Clamshells (both heat-sealed and reclosable). The example is rectangular and clear and opens like a clamshell with a hinge. The two sides overlap slightly, forming a

Plastic Folding Cartons. The example carton is rectangular and opaque. The first image shows the unassembled folding carton, lying flat. The second photo shows the assembled folding carton.

Plastic Folding Cartons. 

Note: Photos are for demonstration purposes only. Rulers in some photos serve as a reminder that all RPPCs must meet certain size requirements. Each plastic container must be independently evaluated to determine whether or not its attributes, evaluated as a whole, qualify it as an RPPC. A product manufacturer should not make a conclusion that their package is or is not an RPPC based solely on one of these photos. If you have questions, contact your assigned RPPC staff or see the contact information at the bottom of this page.

RPPC Exemptions

To make an informed determination as to whether a particular product’s RPPC is exempt, refer to the RPPC regulations, Section 17946.5 and statute, Section 42340.

Note: All container determinations are case-by-case. A product manufacturer that has several products will need to evaluate each product’s RPPC independently.

Determining a Container’s Volume or Equivalent Capacity

One of the factors for determining whether a particular product’s RPPC is regulated is the volume or equivalent capacity that the RPPC is capable of holding. A regulated RPPC has a minimum capacity or volume of 8 ounces up to a maximum capacity or volume of 5 gallons. If you are unsure of a particular RPPC’s total volume or equivalent capacity, consider the following:

• Contact the container manufacturer.
• Work with the engineers within your company.
• Conduct the measurement yourself.

The following may assist you in conducting your own measurement:

• Videos
  • Measurement Demonstration: YouTube (00:08:08) Transcript
  • Determining a Container’s Volume: YouTube, 00:08:54, Chapter 2 of webinar on complying with California’s RPPC law). Transcript
• U.S. Liquid Measure Volume Capacity Calculator
• Formulas to calculate shapes

Note: The identification of, or any resemblance to, particular companies, products, or materials listed on this webpage does not constitute endorsement by CalRecycle and is provided for informational purposes only. CalRecycle is distributing this information in an effort to increase public awareness and knowledge.

For more information contact: Rigid Plastic Packaging Containers, RPPC@calrecycle.ca.gov.