Wine Institute Comments on Proposed SB 54 EPR Packaging Regulations

On Nov. 4, 2024,, Wine Institute provided comments to CalRecycle on proposed regulations to implement the extended producer responsibility (EPR) program under the Packaging Pollution Prevention and Plastic Producer Responsibility Act per SB 54 (Allen, 2022). Our comments highlighted the substantial costs to California wineries (which are also entering the bottle bill program), asked for clarification of the definition of the “producer” term, asked for better accounting for wineries’ role (consumer vs. producer) related to packaging materials used in the production of wine products and expressed appreciation for a transition period. Contact Anna Ferrera for a copy of the comments.

Wine Institute also joined a California Chamber of Commerce business coalition letter addressing a broader number of concerns that asks for flexibility given the short turnaround for the producer responsibility organization (PRO) to “collect funds, invest in material recovery facilities and establish end markets before the first deadline is triggered on January 2028 for 30% of plastic material to be recycled” and to potentially re-evaluate deadlines for adjustments in the program as allowed by law.

SB 54 was intended to require producers of single-use plastic packaging in California to take on greater responsibility for a circular economy that includes higher recycling rates and reducing waste. However, SB 54 is not just about plastic packaging, imposing restrictions on all single-use packaging, known as “covered materials,” under SB 54. The covered materials list was adopted by CalRecycle on July 1, 2024. In January, the Circular Action Alliance was chosen to be the first PRO for the EPR program in California. CalRecycle must adopt regulations to implement and enforce the program by Jan. 1, 2025. For more information on SB 54, see CalRecycle’ s SB 54 web page.

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