SABRC Frequently Asked Questions
General Program Questions
What is RCP?
RCP is a recycled content product. RCPs under the SABRC program are products made of post-consumer recycled content or material derived from products that were purchased, used, and then recycled by a consumer. This recovered material (e.g.paper, or plastic water bottles) becomes feedstock to create new products.
What is required of state agencies under the SABRC mandates?
See the Program Requirements webpage and SABRC Handout.
Do all state agencies have to buy RCPs?
Yes. Statute requires all state agencies to purchase RCPs instead of non-RCPs to conserve and protect resources and improve markets for recycled products.
Are state agencies required to buy RCPs even if they cost more?
Yes. State agencies, if feasible, must purchase the more costly recycled product to meet the solid waste diversion goals. While some RCPs may cost more than comparable non-RCPs, many RCPs cost less. Agencies are still required to purchase RCPs even after they meet their RCP procurement goal.
What are the minimum content requirements for each of the product categories?
See the SABRC Handout.
Is each agency required to purchase products from each of the 16 product categories?
No. Many state agencies do not purchase products from all the product categories. For example, some state agencies may not purchase paint, compost, or tires. If an agency does not purchase any products from a particular category during a reporting period, the agency may report zeros for those product categories on the SABRC annual report.
Are there any other criteria used to define a recycled product?
Yes. Products that are refurbished, remanufactured, or reused are considered 100 percent recycled, regardless of whether they meet the minimum content requirements.
Are state agencies required to have the businesses they purchase products from certify the recycled content of all purchased products, goods, materials, or supplies?
Yes. State agencies must require all businesses to certify in writing the minimum, if not the exact, percentage of post-consumer and secondary material in the products, goods, materials, and supplies offered or sold to the state. This applies whether or not they fall within one of the 16 product categories or which type of contract is used to obtain the product.
Must state agencies require contractors to obtain the recycled-content information regarding all products, goods, materials, or supplies provided or sold?
Yes. All contractors must provide in writing the minimum, if not the exact, percentage of postconsumer and secondary material in the products, goods, materials, and supplies offered or sold to the state, regardless of whether they fall within one of the 16 product categories.
Contractors must also certify the minimum content regardless of the method or type of contract used to offer or sell the product to the state.
If I am purchasing a product that is not one of the 16 product categories, but it is packaged in a plastic container, do I need to report on the packaging container?
No, purchases are for the item only and do not include the packaging.
Do most steel products available today count as recycled-content products?
Yes. Almost all steel products use recycled steel. The methods of manufacturing steel products typically use postconsumer steel in sufficient quantities to ensure that all products qualify as recycled-content products. Unless you have special ordered virgin steel for the manufacture of your specific product, all steel products should be reported as recycled steel products.
Do I need to obtain the Postconsumer-Content Certification Form (CalRecycle Form 74) and other documentation certifying the amount of recycled-content material in steel office products such as chairs, staplers, staples, paper clips, scissors, and hole punches?
No. The Steel Recycling Institute has statistically determined the recycled and postconsumer recycled-content material in all steel products. Steel products made in America meet or exceed the minimum SABRC recycled-content requirements.
Will most compost purchases qualify as recycled-content compost purchases?
Yes. Almost all compost will qualify as recycled-content compost because postconsumer material includes any compostable material and all plant material. If the material is derived from a biological breakdown of organic material and the compost was produced by a waste management facility, the compost will meet the requirements for recycled-content compost.
Requiring the supplier to complete the postconsumer-content certification form (CalRecycle Form74) or other documentation used to certify any amount of recycled-content material will ensure that the product meets the requirements.
Why is it hard to find recycled interior paint at big box stores?
In California, it is generally accepted that low-VOC (volatile organic compounds) paints are ≤50 g/L and is preferred or required for interior use. Typically, only exterior paint is available due to the associated costs.
Recycled-content low-VOC paint is available as a specialty product only made when ordered in sufficient quantities. We list manufacturers on the SABRC Product Categories page.
Should state agencies keep copies of all the Postconsumer-Content Certification Forms (CalRecycle 74) and other documentation for products?
Yes. Statute requires state agencies to certify the amount of recycled material in all products. SABRC compliance is also evaluated during purchasing delegation reviews.
Is there a records retention schedule of the SABRC annual reports?
CalRecycle and the SABRC program does not dictate a specific schedule. Each state agency has its own schedule of retention that dictates how long it shall keep various records/files.
Are take back programs for various products besides toner and ink cartridges SABRC compliant?
Yes, with the passage of AB 661, Section 12217(e) of the Public Contract Code states a state contract may require that the vendor take back the product for proper management after it has been used. If there is a take back program for products with or without meeting the minimum PCRC content, those products would be considered SABRC compliant.
Is the new language in AB 661 for purchasing postconsumer recycled content products within 10% greater total cost a preference for state agencies or a requirement?
Section 12201(c) of the Public Contract Code reflects the requirement to purchase recycled content products over non-recycled content products no matter if those products meet the minimum PCRC requirements.
SABRC Reporting Questions
Is there a tracking tool available?
Information on tracking purchases can be found on the SABRC Program Requirements page including the CalRecycle-created spreadsheet.
Does each state agency track and report only for the purchase of products within the 16 identified categories?
Yes. The annual SABRC report reflects both RCP and non-RCP purchases in the 16 categories. Products that cannot be classified within one of the 16 product categories should not be included in the report.
Is each agency required to track and report ONLY the reportable RCP purchases?
No. Within the 16 product categories, both RCP and non-RCP purchases must be tracked. Tracking both RCP and non-RCP purchases allows agencies to provide the information needed for the annual SABRC report and to calculate whether the agency has attained the mandated RCP procurement requirements.
Should my agency be tracking the packaging that comes with our SABRC-compliant purchases? For example, our state agency purchases cleaning solutions and chemicals where the liquid is non-reportable, but it is packaged in a plastic jug which falls in under a reportable product category.
No. The packaging of your agency’s purchased product should not be included with your SABRC reported purchases even though it falls under a reportable product category.
How are taxes and/or shipping included in the totals?
The statute did not provide clarity on whether taxes and shipping are part of the costs to be reported. Therefore, state agencies have discretion over whether they report taxes and shipping as part of the total dollar spent. State agencies may choose to include or omit taxes and shipping as part of the overall costs reported.
How should an agency report on products received through a formal interagency agreement or through another arrangement, such as with the Office of State Publishing (OSP) or Prison Industry Authority (PIA)?
For print jobs performed by OSP, the agency that specifies the paper to be used for the print job, reports for the paper used in that job.
For example, if your agency specifies the type of paper required for the job, then your agency would report the paper used. If your agency does not specify the type of paper required for the job, and OSP makes the decision on the type of paper to be used, then OSP would report for the paper.
In the case of purchases made from PIA, the agency that is making the purchase will report for those products. PIA should not report for purchases of materials that are used to make products for other agencies, because that would result in double-counting (first by PIA for the materials and then by the agency purchasing the products made from those materials).
It is always best to coordinate with the other agency at the time the job or agreement is being discussed, so that both parties understand ahead of time who will report for the materials being used.
When an agency obtains products/materials through a service, maintenance, or a building construction project, should they report the dollars spent on the actual cost of the products and materials or the total cost of the contract?
An agency should only report the dollar amount of the actual products and materials obtained through the contract, not the entire value of the contract.
For instance, if an agency has a printing job performed, it must have the printer itemize the cost of the paper out of the total cost of the print job and certify the recycled content of the paper. The agency then reports the dollar amount of the paper.
In the case of a maintenance contract involving painting a building, the agency must require the painter to itemize the cost of the paint out of the cost of the entire paint job and certify the recycled content of the paint. The agency then reports the dollar amount of the paint purchased for the project.
Do products, materials, goods, and supplies purchased for new construction, renovation, and tenant improvement projects need to be tracked and reported under SABRC even though the general contractor makes the purchases?
Yes, all dollars spent on reportable products in building construction and renovation, public works, service contracts, and capital outlay projects must be included in the SABRC annual report.
Should an agency report the purchase of oil, antifreeze, or tires when the DGS Fleet Administration services the vehicles for that agency?
No. DGS will report the oil, antifreeze, and tire purchases on their department report.
How do I decide which product category to use to report products made from more than one material?
Should agencies report dollars spent on toner or printer cartridges in the SABRC annual report?
Yes, they should be reported under the plastic products category. Toner or printer cartridges that meet one of the three criteria, meet the requirements of SABRC compliance:(1) Have 20% post-consumer material in the new cartridge,(2) Is a remanufactured cartridge, or(3) Is backed by a vendor-offered program that will take back the cartridge after its useful life and ensure that the cartridge is recycled.
Should an agency report battery purchases in the metals or plastic category?
No, batteries should not be reported in any of the SABRC product categories. Batteries are created with a wide variety of materials that do not uniformly fall in the product categories. If vendors and purchasers are using the CalRecycle Form 74 for product certifications, you would enter N/A for batteries.
What does CalRecycle do with the SABRC Annual Reports?
The SABRC annual reports are analyzed to monitor and track state agency purchasing, compliance with RCP procurement goals, and are the basis for consultations with non-compliant agencies to ensure future compliance. The data gathered from SABRC reports show purchasing trends across state agencies, departments, boards, and offices are compiled into a statewide report that is posted on our website and the State of California’s Green Buyer website.
How do I Certify Postconsumer Recycled-Content?
State agencies, including agency’s contractors, must require all suppliers to certify the postconsumer recycled content of all products offered or sold to the state. This includes purchased materials and supplies used in their contract work if those items fall within the eleven product categories.
Postconsumer-Content Certification Form CalRecycle Form 74 Guidance: Word | Fillable PDF
All certification documentation must be obtained and kept on file. Periodically, agencies will be required to show their certifications to the Department of General Services’ Purchase Delegation auditors.
How do I get the information about use the Postconsumer-Content Certification form?
State agencies should provide their suppliers and contractors with the Postconsumer-Content Certification form (CalRecycle Form 74 Guidance: Word | Fillable PDF). This form is a tool provided to help capture the required information.
How do I get the information about the Supplier’s Catalog or website?
A copy of a page within the supplier’s catalog or their website may be used for product certification. This will be an easier way to capture the postconsumer content of a product.
How do I get the information about product labeling and packaging?
Product labeling and packaging may be used for product certification if the postconsumer content information is provided.
How do I specify what I need on specific contracts?
- Utilize boilerplate language. To obtain product recycled-content information more efficiently, state agencies can develop boilerplate language (sample boilerplate language is provided below). This language should be put into the contract or solicitation among the paragraphs addressing other preferences, such as the Small Business and the Disabled Veterans Business Enterprise, and included with the specifications on the purchase document. The language should be set apart, clearly labeled, and in a prominent location so that it is easily seen and read.
- This language should be added to all contract documents including Invitation for Bids; Service and Public Works Contracts; Delegation Release Orders Std. 65; Printing Requisitions Std. 67; Requests for Proposals; Informal Solicitations; Purchase Estimates Std 66; CAL-Card Orders.
- Sample boilerplate language for procurement related contracts and forms.
- Contract language: This language addresses the overall SABRC requirement, including the supplier recycled-content certification.
- “The State of California is required to purchase recycled-content products (RCPs) rather than nonrecycled products whenever price, quality, and availability are comparable. Furthermore, each state agency, including the agency’s contractor(s), is required to purchase RCPs in sufficient quantities to ensure that mandated RCP procurement goals are attained within eleven product categories. The eleven product categories and their respective minimum postconsumer-content requirements are outlined in SABRC Handout. In order to help state agencies identify all reportable purchases and all the reportable RCP purchases, suppliers and agency contractors are mandated by the Public Contract Codes to certify the minimum, if not the exact, postconsumer recycled-content material in the products, materials, goods, and supplies offered or sold to the state.”
- Recycled paper language: This language is for specifying print orders using recycled-content paper.
- “The [agency name] requires that all printing jobs, including printing jobs through [state agency’s contractor], be printed on recycled content papers. Recycled-content papers are defined as papers containing a minimum of 30 percent postconsumer fiber by weight. All papers used in the performance of a print job for [agency name or agency’s contractor name] shall be recycled-content paper. The exact grade and postconsumer fiber content of the papers used for each print job shall be specified by [agency name or agency’s contractor name].”
- The recycle logo or “chasing arrows” cannot be used on the printed material unless the paper contains a minimum of 30 percent postconsumer material. If paper meets the 30 percent requirement, ask that the recycling logo be printed on the project.
Information on Recycled Paint Myths
- Is recycled paint is more likely to crack, peel, or blister?
False. The performance of recycled paint is comparable to standard paint. Peeling and blistering is commonly due to improper surface treatment before application or moisture present in the substrate. Cracking usually occurs when coats of paint are not allowed to cure/dry completely before the next coat is applied.
- You cannot use recycled paint in hot conditions or desert environments.
False. Recycled paint holds up well in hot weather. Some painting contractors recommend applying paint in warmer temperatures to help with adherence. For example, a lot of recycled paint is sold in Africa in extremely dry, hot environments with no complaints about performance. In addition, recycled paint is sold in the desert regions of Southern California and Arizona.
- Recycled paint is only available in dull colors and sheens, and colors vary from batch to batch.
False. Recycled paint comes in a variety of standard colors and sheens. Most recyclers will custom tint large batches to meet a customer’s needs and can also match colors from already-painted surfaces. Each batch is tested for quality and color consistency.
- I can’t use recycled paint for Direct-to-Metal applications.
False. Recycled-content Direct-to-Metal (DTM) paints are available and perform similarly to standard DTM paint. For example, the City of Santa Monica and Big Bear use recycled-content DTM paints on trash bins and roll-off bins.
- The extra hassle of locating recycled paint is not worth the cost savings.
False. Recycled paint is much less expensive than most standard paints. On average, a high-quality recycled paint costs $10-15 per gallon, whereas a gallon of comparable standard paint can often cost as much as $30-50+ per gallon.
- Recycled paint has a shorter shelf-life than standard paint.
False. An unopened can of paint (whether standard or recycled) can last for decades if it is stored in a dry, cool (but not too cold), dark place. It’s best not to leave paint in direct sunlight, outdoors, or in a moist location. Visit PaintCare’s website for tips about how to properly store paint to ensure it lasts.
- Recycled paint cannot be used in environments close to the ocean.
False. Recycled paint is often utilized near the ocean, which has no impact on the performance of recycled paint. For example, recycled paint is used in southern California near the ocean and in China and the Philippines in areas with heavy rain.
- Recycled paint is not available near me.
False. Recycled paint is sold statewide in various retail locations, as well as available directly from recyclers. See PaintCare’s list of locations (PDF download) that sell recycled paint in California to find where to purchase recycled paint near you.
- Recycled paint is lower quality than virgin paint.
False. Recycled paint is tested for performance and quality including pH, viscosity, sag resistance, sheen, coverage, and fineness of grind. The performance and quality of recycled paint is comparable to standard paint.
- Recycled paint is not suitable for interior use.
False. There are low-VOC recycled paints that are less than 50g/L VOC content and suitable for interior use.
What are textiles, what are general textile wipes, and how should we report?
All textiles should be reported, including, but not limited to blankets, sheets, towels, safety equipment, clothing, flags, general purpose textile wipes. See the Clothing and Textile category at CalPIA as well as the statewide contract 1-22-72-02 for Textiles – Towels, Washcloths, Cotton and Wool Blankets, and Acrylic Blend Blankets. General textile wipes are created by using postconsumer textiles (used clothing and linens) and making wiping materials. These are used for wiping and polishing cloths for industrial and commercial applications, wiping textiles for cleaning and absorbing elements like oil and grease, wiping textiles offer a green alternative to other options, like paper products and laundry services. The rags absorb better than paper, reduce the use of virgin materials, and, in a drought-stricken state, save water. Example uses are in automotive, janitorial, and other industrial and commercial applications.
As a Vendor, how can I sell my products to state agencies?
Q: I would like to sell my product to California state agencies. Who do I contact?
Visit CalRecycle’s Vendor Selling site or the California Department of General Services ‘How to do business with the State of California’.
Q: I am a bidder completing a Request for Proposal (RFP) response for a state agency. I do not know how to complete the information on SABRC or how this relates to my product.
If you are responding to an RFP and submitting a response, contact the state agency regarding its specifications and requirements for the product.
For examples, please see the Guidance on Form 74 for Vendors.
Q: I am a vendor / manufacturer who supplies products to the state. I keep receiving a Form 74 for products purchased. How do I complete the form?
Please see the Guidance on Form 74 for Vendors.
Q: I would like to sell my food product to the state and classify my product as SABRC-compliant.
Food products do not fall into one of the 171 SABRC categories. The food product itself is the product being purchased and the packaging would not be applicable to a SABRC category.
Q: I would like to sell electronics to the state. How do I make sure the products are SABRC-compliant?
Information Technology (IT) Electronics are categorized under the “Plastic” SABRC product category. Plastic products should contain a minimum of 10 percent post-consumer recycled content to be considered SABRC-compliant. For questions on IT Electronics and environmentally preferable purchasing, refer to the Department of General Services’ purchasing standards.