CalChamber Backs Circular Action Alliance to Become California’s Producer Responsibility Organization

The California Chamber of Commerce announces its support for the Circular Action Alliance to become California’s Producer Responsibility Organization in accordance with SB 54 (Allen; D-Santa Monica).

The CalChamber led the business coalition last year in negotiating to remove a costly $9 billion a year tax and plastic packaging ban initiative from the ballot.

The recycling law enacted in place of the ballot marked a pivotal moment in California’s efforts to revamp its recycling program, introduce an Extended Producer Responsibility (EPR) program specifically targeting single-use packaging and avoid the largest tax increase in the state’s history. The EPR program established under the new law requires businesses using single-use packaging to take greater steps to reduce plastic packaging and recycle all single-use packaging rather than sending the material to landfills.

One of the very first compliance obligations for the business community is to form and join a Producer Responsibility Organization, also known as a PRO, that will assist businesses with reducing waste and increasing recycling of their packaging.

About the Circular Action Alliance and Need for a PRO

California’s new recycling law requires the Department of Resources Recycling and Recovery (CalRecycle) to approve one PRO to develop a recycling plan with which all businesses selling single-use packaging will need to comply.

With applications due to CalRecycle by January 1, 2024, the CalChamber believes the Circular Action Alliance (CAA) is best positioned to be approved and serve the diverse business community with their compliance obligations.

CAA is a 501(c)(3) nonprofit producer responsibility organization formed in 2021 in response to an increasing number of states, including California, mandating EPR for packaging.

Earlier this year, CAA became the first PRO in the United States to be approved for administering an EPR program for paper and packaging in Colorado. CAA also was approved as the single nonprofit PRO on the State Producer Responsibility Advisory Council in Maryland. CAA is currently actively seeking approval in Oregon and Maine.

As an increasing number of states mandate EPR for packaging, companies will rely more and more on the assistance of a PRO to navigate the evolving landscape of recycling regulations across the country. This need is particularly pronounced in California, where noncompliance with laws like SB 54 can result in hefty fines and potentially packaging bans for noncompliance.

CAA’s vision of unifying the PRO framework nationwide as companies contend with EPR in multiple states will provide significant benefits to the business community, including increased efficiencies, lower operating costs and more consistent guidance.

The CalChamber believes that the Circular Action Alliance, with its technical expertise, producer toolkit and established infrastructure, is California’s top choice to serve as the state’s PRO.

Staff Contact: Adam Regele

Adam Regele
Adam Regele joined the CalChamber in April 2018 as a policy advocate specializing in environmental policy, housing and land use, and product regulation issues. He was named a senior policy advocate in April 2021, and promoted to vice president of advocacy and strategic partnerships in March 2023. He came to the CalChamber after practicing law at Oakland-based Meyers, Nave, Riback, Silver & Wilson, PLC, where he advised private and public clients on complex projects involving land use and environmental laws and regulations at the local, state and federal levels. Before entering private practice, Regele served as a federal judicial law clerk to the Honorable Edward J. Davila of the U.S. District Court, Northern District of California. Regele earned a B.S. in environmental science at the University of California, Berkeley, and a J.D. from UC Hastings College of Law, where he was symposium editor and research and development editor for the Hastings West-Northwest Journal. See full bio.