California’s Rigid Plastic Packaging Container Proposed Regulations Workshop Webinar – May 17, 2011

I attended the workshop via webinar last Tuesday and came away with some points of interest regarding the proposed changes. California Department of Resources Recycling and Recovery (CalRecycle) held two segments; one was to have a discussion about the revised definition of “Post-Consumer Material” and the other for the changes in the proposed definition of an RPPC based on the public comments from the previous workshop on April 8. The Word documents and PPT presentations showing the proposed changes can be found on the CalRecycle website (link at end of this post).

The most salient points that I took away from it are the following:

Post-Consumer Material section:

• Post-Industrial waste, packaging re-used in-house during the manufacturing process (e.g. regrind), is no longer included as part of the definition of post-consumer materials
• RPPCs holding obsolete or unsold product can now be considered for post-consumer materials
• Finished plastic packaging rejected by the container manufacturer or the production manufacturer can be considered post-consumer materials.

Note that for the last two above, there were several public comments regarding the tracking and confirming the validity of the classification of the materials from the manufacturer side, so there may be additional changes in the future. (Although, the CalRecycle personnel seemed to feel the existing wording covered the manufacturers’ concerns.)

Definition of an RPPC section:

• One of the big issues was the inclusion in the definition of the term multiple re-closures. This seemed to impact thermoformed/vacuum molded clamshell packaging the most. The revised definition will remove the statement “capable of multiple re-closures” so that ALL clamshells would be included. Previously, one could read the definition to mean that clamshells that were heat-sealed shut would not be included as they could not be re-closed.
• Another was the addition of the phrase “are composed entirely of plastic except that rigid plastic packaging containers may have” now includes packages with caps, lids, labels, handles, hinges, etc made of non-plastic materials and additives such as pigments, colorants, fillers, and stabilizers that are part of the plastic polymer compound.
• The calculation of capacity/volume was also clarified for better understanding of which containers fall into the 8 oz – 5 gallon range of the existing regulation.

For more info, check the handout on the website. http://www.calrecycle.ca.gov/laws/Rulemaking/RPPC/default.htm

The idea behind these changes was to level the playing field amongst RPPCs.