Covered Entities

California law requires a covered entity, or a stewardship organization established on behalf of a group of covered entities, to develop and submit a stewardship plan(s) to CalRecycle. See Public Resources Code (PRC) section 42030(f) for the definition of “covered entity.”

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)).
  • 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 visit the Law page.

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)
1800 M Street, NW Suite 400 South
Washington, DC 20036

Stanton J. Barrett, Vice-President, Membership and Communications

The Drug Take Back Solutions Foundation (pharmaceuticals and home-generated sharps waste)
Kirk Herweck, Director of Consumer Drug Take-Back
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.

For more information contact: Pharmaceutical and Sharps Unit,