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 on the CalRecycle website.
- 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. [See Public Contract Code sections 12200-12217.]
- Are state agencies required to buy RCPs even if they cost more?
Yes. PCC section 12217(c) states that a state agency, if feasible, must purchase the more costly recycled product to meet the solid waste diversion goals of Section 41780. While some RCPs may cost more than comparable non-RCPs, many RCPs cost less.Even after an agency meets their RCP procurement goal, they are still required to purchase RCPs rather than non-RCPs.
- What are the minimum content requirements for each of the product categories?
See SABRC Product Categories webpages or the SABRC Handout.
- Is each agency required to purchase products from each of the 11 product categories?
No. Many state agencies do not purchase products from all of 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 or not 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. Statute requires all state agencies to 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, regardless of whether or not they fall within one of the 11 product categories and regardless of the method or type of contract used to obtain the product. [see PCC Section 12205, 12320(1)].
- Must state agencies require contractors to obtain the recycled-content information regarding all products, goods, materials, or supplies provided or sold?
Yes. Statute requires all state agencies to require all contractors to obtain 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 or not they fall within one of the 11 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. This information may be furnished by the contractor on the Postconsumer-Content Certification Form (CalRecycle form 74). The information is required, although the contractor need not use this form. However, the form has been designed to collect all of the necessary information in an efficient manner. [See PCC Section 12205, 12320(a)].See “How do I get the information?” on our Certifying Postconsumer Recycled Content webpage or “Verifying Postconsumer Recycled Content” and “Acceptable Postconsumer Recycled Content Verification Options” in the SABRC Handout.
- Do most steel products available today count as recycled-content products?
Yes. Almost all steel products use recycled steel. The two methods of manufacturing steel products typically use postconsumer steel in sufficient quantities to ensure that all products qualify as recycled-content steel 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/or 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. As long as 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. However, requiring the supplier to complete the postconsumer-content certification form (CalRecycle Form74) and/or other documentation used to certify any amount of recycled-content material in a product will ensure that the product meets the minimum content requirements.
- Should state agencies keep copies of all the Postconsumer-Content Certification Forms (CalRecycle 74) and/or 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.
Specific Questions on the SABRC Annual Reporting
- Is there a tracking tool available?
See “Purchasing and Tracking Tools” on our website.
- Does each state agency track and report only for the purchase of products within the 11 identified categories?
Yes. The annual SABRC report reflects both RCP and non-RCP purchases in the 11 categories. Products that cannot be classified within one of the 11 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 11 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 or not the agency has attained the mandated RCP procurement requirements.
- How are taxes and/or shipping included in the totals?
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 total dollar spent. CalRecycle recognizes that it is easier to calculate taxes and shipping on a single item purchase than to calculate individual taxes and shipping costs per item on a large order. 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 Office of State Publishing, 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).
Remember, 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 actually 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?
See Composite Product Reporting for SABRC in the online SABRC Manual.
- Should agencies report dollars spent on toner cartridges in the SABRC annual report?
Yes they should be reported under the plastic products category. Toner cartridges that meet one of the three criteria meet the requirements of SABRC compliance:(1) Have 10% post-consumer material in the new cartridge,(2) Is a remanufacturered 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.
- 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.