Covered Entities

Covered Entity Requirements

Covered entities are subject to statutory and regulatory requirements, including, but not limited to:

• Submittal of product lists to the California State Board of Pharmacy (see PRC section 42031(a)(1)).
  • Submittal of updated lists to the California State Board of Pharmacy on or before January 15 of each year (see PRC section 42031(a)(2)).
  • Respond to the California State Board of Pharmacy’s letters of inquiry pursuant to PRC section 42031(d), if necessary.
  • Please contact BOPstewardship@dca.ca.gov for questions.
• Establishment and implementation of a stewardship program for pharmaceuticals or for home-generated sharps, as applicable, either on its own or as part of a group of covered entities through a stewardship organization.
• Submittal of a stewardship plan to the California State Board of Pharmacy prior to submitting to CalRecycle by July 7, 2021.
  • Duration of time the California State Board of Pharmacy takes to review a stewardship plan does not count toward this deadline.
  • Covered product(s) must be subject to an approved stewardship plan by January 7, 2022 (see PRC section 42031.4(a)).
• Submittal of an initial stewardship program budget, an annual budget, and an annual report to CalRecycle, either individually or through a stewardship organization.
• Payment of all administrative and operational costs associated with establishment and implementation of the stewardship program in which a covered entity participates, either individually or through a stewardship organization.
  • Payment of an administrative fee that covers any regulatory costs incurred by a state agency in administering and enforcing the law.
• For more information, including key definitions, please see the law.

Approved Stewardship Organizations

The list is not an endorsement or recommendation by CalRecycle. Per statute, a covered entity may submit a stewardship plan independently, or a group of covered entities may establish a stewardship organization and submit a stewardship plan to CalRecycle (see PRC section 42030(w)).

The stewardship organizations listed below operate under stewardship plans approved by CalRecycle.

MED-Project, Pharmaceutical Product Stewardship Work Group (pharmaceuticals and home-generated sharps waste)
https://ppswg.org/
1800 M Street, NW Suite 400 South
Washington, DC 20036

CONTACT:
Stanton J. Barrett, Vice-President, Membership and Communications
sbarrett@ppswg.org
202-580-6298

The Drug Take Back Solutions Foundation (pharmaceuticals and home-generated sharps waste)
CONTACT:
Kirk Herweck, Director of Consumer Drug Take-Back
take-back@inmar.com
1-800-350-0396 Option 5

This page provides a brief overview and is not intended to provide a comprehensive list of legal requirements. Please refer to statute and regulations for a complete list of requirements. Users are encouraged to seek the assistance of legal counsel to comply with applicable state law based on their pertinent facts and circumstances.