Local Jurisdiction and Recycling Service Provider Guidance

Plastic Pollution Prevention and Packaging Producer Responsibility Act

 

The following provides guidance to help local jurisdictions and recycling service providers understand and meet the requirements of California’s packaging producer responsibility law. 

Local jurisdictions and recycling service providers are essential to California’s materials management and recycling systems. Under California’s packaging producer responsibility law, curbside collection and recycling programs must collect all covered materials included on the Covered Material Categories (CMC) List that are identified as recyclable or compostable. 

The law also allows local jurisdictions and recycling service providers to obtain an exemption from collecting specific covered materials if collection is impractical, or if a rural county or jurisdiction adopts a resolution to exempt that jurisdiction or recycling service provider from these requirements.

While jurisdictions play an important role in these requirements, California law makes it clear that ratepayers shall not pay implementation costs. All costs of implementation — including the requirement to add covered materials to local collection and recycling systems — must be the responsibility of the producer responsibility organization (PRO).  

Extended producer responsibility (EPR) is meant, in part, to ease future burdens on local jurisdictions as they manage single‑use plastic food service ware and packaging. 

Extensions and Exemptions for Local Jurisdictions

or Recycling Service Providers 

Local jurisdictions and recycling service providers may request extensions or exemptions from certain covered material collection and recycling requirements, as allowed under PRC section 42060.5 and 14 CCR section 18980.11.1.

  • All applications must be submitted through CalRecycle’s Packaging Extended Producer Responsibility Reporting System (PEPRS).  
  • The PRO must review all extension or exemption applications before they are submitted to CalRecycle.  
  • When a jurisdiction or service provider submits an application in PEPRS, the system automatically routes it to the PRO. 
  • Submitting through PEPRS meets the PRO review requirement and notifies CalRecycle that the process has started, ensuring the applicant is not in violation. (see CCR section 18980.11.1(d)). 
  • The PRO uses its own PEPRS account and dashboard to review applications, submit final comments, or contact the applicant if clarification or additional documentation is needed. 
  • Following the PRO’s review, the applicant can submit the request to CalRecycle via PEPRS (including any comments from the PRO).
  • CalRecycle will notify applicants of its determination or may contact the applicant if clarification or additional information is needed.

PEPRS Access for Local Jurisdictions

To access PEPRS, local jurisdictions must submit a Packaging EPR Contact Request Form to identify an authorized representative. This representative will:

  • Submit the local jurisdiction exemption application.
  • Receive notifications and updates for applications submitted by the jurisdiction or a recycling service provider.

After CalRecycle verifies the jurisdiction contact, PEPRS will send the authorized representative a confirmation email and an invitation to create a WebPass account (if they do not already have one).

PEPRS Access for Recycling Service Providers

Recycling service providers seeking an extension or exemption must first create a  WebPass account to access PEPRS.

CalRecycle will post approved extensions and exemptions under PRC 42060.5(b) and (c) on a public webpage. Listings will identify the jurisdiction or recycling service provider and the specific covered material or covered material category involved. Approved applicants are not required to collect the listed covered material for recycling or composting.

Resolution Adoption by a Rural County or Rural Jurisdiction 

A rural county or rural jurisdiction that adopts a resolution under PRC section 42060.6(c) must notify CalRecycle within 14 calendar days of the adoption date.

Resolutions may be emailed to packaging@calrecycle.ca.gov or submitted through PEPRS. See PRC section 42060.5 and 14 CCR section 18980.11.2 for more information.

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Tools and Resources

SB 1383 and SB 54 Chat with CalRecycle
The webinar covers common questions raised by jurisdictions, including:

  • Collection program requirements
  • Available CalRecycle support
  • Enforcement processes and
  • SB 54 exemptions

It also outlines how SB 54 covered material categories align with existing collection programs and features local representatives who shared practical approaches for planning and evaluating jurisdictional programs.

Second Webinar on SB 1383 and SB 54 Chat with CalRecycle
This webinar highlights StopWaste’s strategy for advancing local jurisdiction compliance with SB 54, including its approach to categorizing covered materials or determining which CMCs require exemptions. It also provides CalRecycle’s updated guidance on the Jurisdiction and Recycling Service Provider Exemption Process for SB 54 and features a panel discussion followed by a question-and-answer session.