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Proposing an Operational Approach to AB 1080 & SB 54

The American Chemistry Council (ACC) agrees with the objectives of AB 1080 (Gonzalez) and SB 54 (Allen).

To help AB 1080 and SB 54 move from “aspirational to operational” ACC is proposing simple, yet important amendments to address the following issues:


Challenge: Improving Recycling Infrastructure

Achieving higher recycling rates will require improvements in the state’s recycling infrastructure through better collection, sorting and processing of recyclable materials.


ACC recognizes the role industry needs to play to help these efforts succeed and has proposed raising nearly $100 million in new revenue via an industry-financed recycling infrastructure investment program.

Challenge: Ensuring Litter Reduction Not Substitution

To promote the move to a circular economy and increase mindful use of materials, it’s important to remember that ALL MATERIALS have environmental impacts. Therefore, it’s key to evaluate the use of any and all types of packaging, not to single out a particular packaging type.

New rules to address litter or marine debris should also consider how likely replacement products will be managed. Data shows that banning one particular material type does not reduce litter but merely results in changing the composition of the litter stream. This is why the State Water Resources Control Board, when it adopted its statewide trash reduction policy, specifically highlighted the need to address “all trash” not simply focusing on individual product bans.


ACC’s proposed amendments would require Cal Recycle to take into consideration the State Water Board’s Trash Policy so that future regulations result in litter reduction and avoid litter substitution.

Challenge: Encouraging Packaging Efficiency

Both bills establish “source reduction,” a new requirement for manufacturers to use as little packaging as necessary for their products. Unfortunately, the bills would not allow manufacturers to use plastic packaging in order to comply with this requirement. Even if a plastic package uses the least amount of material, is fully recyclable, and has the lightest environmental footprint it would not be allowed in order to comply under this provision.


ACC is proposing a simple amendment that would allow manufacturers to comply by demonstrating, via internationally recognized life-cycle data, that its use of plastic packaging is the least detrimental and the most efficient packaging choice.

Challenge: Avoiding Regrettable Substitutes

Any recycling rate requirements must apply to the broadest universe of packaging as practical so as to not incentivize a switch from plastic packaging to another material type that may, for example, dramatically increase the generation of greenhouse gas emissions.

As drafted, both bills incentivize the use of heavier/bulkier packaging that may have greater carbon and water impacts, require more material to produce, more water or energy to manufacture, and likely more trucks to deliver to retail outlets.


Particularly in California, water and carbon impacts must be factored into any new recycling requirements, ACC has drafted amendments that put all packaging materials on a level playing field.

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