Worried About SB-54 and EPR Compliance? Here's Why Your Company Should Register for the Producer Responsibility Organization Now

If you're a company wondering whether you need to register for the Producer Responsibility Organization (PRO) to comply with California's new packaging legislation SB-54 and SB-343, the safe answer is likely yes.

As the Sustainability Director at Atlantic Packaging, North America's largest privately held packaging company, Caroline DeLoach spends most of her days helping brands shift to more sustainable materials and has keen insights into the evolving regulatory landscape.

Atlantic Packaging, after all, is one of the only packaging companies in the world to earn an "A" grade from CDP, and Atlantic Packaging President Wes Carter was appointed to Cal Recycle's SB-54 advisory board, Caroline is as up to speed on this legislation as anyone. 

She offers this essential advice. 

Why Registering for the PRO is Essential

California's SB-54 and SB-343 mandate that producers take responsibility for the packaging of their products. This means that if your brand's logo appears on the packaging, you are likely considered an "obligated producer" and must comply with these new laws.

Key Points to Consider

  • Who is a Producer?

    • Generally, the producer is the brand whose logo appears on the packaged good being sold.
    • This includes companies selling products with their brand on the packaging.
    • There are exceptions, including certain small businesses and agricultural producers, which each statute details.
  • Current Obligations:

    • If you are selling a product with your logo on it in California, Oregon, or Colorado, you are likely obligated under these laws.
    • The Circular Action Alliance (CAA) is the named Producer Responsibility Organization (PRO) in these states and will likely extend to other states.

Steps to Take Now

  1. Register with the Circular Action Alliance (CAA) by July 1, 2024:

    • No Cost to Register: There is no cost to register with CAA.
    • Know Your Obligations: By registering, you will receive updates on whether you are obligated, important deadlines, the type of data you need to gather, and legislative updates.
  2. Why You Should Register Even if Unsure:

    • Access Resources: Gain access to resources that will help you determine if you are an obligated producer.
    • Stay Informed: Keep up-to-date with the latest legislative changes and compliance requirements.
    • Minimize Risk: Avoid potential penalties by understanding and fulfilling your obligations.
  3. Benefit from Early Registration:

    • Prepare in Advance: Early registration helps you prepare for compliance and avoid last-minute rushes.
    • Peace of Mind: Ensure you are not inadvertently missing out on critical information that could affect your business.

Registering with the CAA is a proactive step that offers numerous benefits, from staying informed to minimizing compliance risks. Caroline DeLoach emphasizes that if you're selling products in California or planning to, it’s wise to register now and ensure you're prepared to meet the new legislative requirements. Don't wait until it's too late—take action today to secure your business's future compliance.

For more information, visit the Circular Action Alliance website and start your registration process now. 

Visit our EPR page for more background on SB-54 and SB-343. 

And if you're trying to navigate the upcoming sustainable packaging laws being implemented, feel free to reach out to our transition team at team@anewearthproject.com

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