The Toy Association Protects Industry Interests During California EPR Program Rulemaking

EPR Toy Association

A coalition group organized by the California Chamber of Commerce (CalChamber), of which The Toy Association is a member, submitted comments to the California Department of Resources Recycling and Recovery (CalRecycle) regarding California’s SB 54, the largest comprehensive packaging EPR (extended producer responsibility) program in the country. As part of the coalition, the Association is providing the toy industry’s perspective throughout the rulemaking process for the proposal.


As-is, California’s SB 54 will significantly affect the toy industry, including restricting what types of packaging can be used in the state, how new packaging materials can be added as technology advances recyclability, requiring the industry to meet source reduction mandates, and imposing eco-modulated fees for different material types. Staff has been working with the State Government Affairs and Environmental Sustainability Committees, and encouraged the industry at large to provide their input, to effectively address industry priorities on this issue.


In the comments, the coalition outlines issues like ambiguous or undefined terms, lack of clarity on exemptions, not including information on compostable packaging materials, and the aggressive compliance timeline outlined in the proposal — expressing concerns about the burden it poses on the industry, especially amidst inflationary pressures — and more. Click here to read the full document.


SB 54, also known as the Plastic Pollution Prevention and Packaging Producer Responsibility Act, establishes new regulations for single-use packaging and plastic food service ware, implemented through an EPR program. The legislation shifts the plastic pollution burden from consumers to producers and raises an additional $5 billion from producers over 10 years to address the environmental impacts of plastic pollution.


The Toy Association will continue to keep the industry apprised of developments on this EPR issue. For more information on The Toy Association’s advocacy initiatives at the state level or to join the State Government Affairs Committee, contact The Toy Association’s Erin Raden.


-Original piece written by The Toy Association-